Policy SP1: Presumption in Favour of Sustainable Development

Presumption in favour of sustainable development, when applied to Colchester considers the number of additional homes, but does not address existing (due to development over past 15 years) Infrastructure shortfalls or existing shortage of hospital beds, or given aging population shortage of social care provision is some areas, example West Mersea predominately aging population has no care homes. Thus proposed plan is not sustainable

The University of Essex fully supports the policy and the Borough Council's commitment to achieving sustainable development and to working with applicants and developers in order to 'find solutions' so that, wherever possible, development proposals, which improve economic, social and environmental conditions in the area, can proceed.

We object to the presumption in favour of sustainable development as this plan is clearly and demonstrably unsustainable in respect of the garden Communities in particular.
The land for the East Garden Community is rated, according to the AECOM appraisal, as being Grade A farmland. Over 80% of the site is classified as being the most productive in the South East. Any notion of sustainability must counter for long term issues such as food security. Environmentally it is accepted that locally, or even nationally, produced food sources are vital.
Only 17% of the residential dwellings are earmarked for 'local need'. Long term inward migration to North Essex is not sustainable.
This plan suggests 2500 houses raising to 9,000 though the lifecycle of the following local plan to 2048. This is a fundamental flaw as judgement is being passed on 2500 houses and there is no scope within this decision-making process to limit future growth on the grounds of unsustainable.
The finances - whilst discussed elsewhere in this submission - are not sustainable beyond the current housing markets high stock. With the reduction in house prices directly comparable with distance from the London 'bubble' any reduction would undoubtedly see an adverse impact on the provision of necessary infrastructure. Notwithstanding the substantial risks to the 'wish list' of infrastructure imbued by a developer's ability to cheat the planning process.
This is not the blueprint of a sustainable standalone community able to provide a localised self-sustaining lifestyle. The lack of community assets is staggering. Where is the provisions for faith buildings, cemeteries, allotments, village halls? Without a sense of place, purpose, and belonging this is merely a dormitory estate. That is unsustainable and against all that Garden Communities are supposed to be.
If it was truly sustainable then why have we suffered an appalling lack of engagement from our local authorities? There is a deep sense of mistrust as our questions remain unanswered and our ability to help shape our area is continually denied. Colchester Borough Council seeks only to tell us what they are doing and not engage on improving the plan and Tendring completely ignore us, offer a different plan to Colchester and have not even attempted to reach out to us.
Furthermore, the adverse impact does not outweigh any perceived benefits. For the following reasons.
Unsound as we should not have to meet unmet demand from Tendring or Braintree.
The bias on judging this plan on 'legal compliance' when the bodies proposing this scheme are the same ones that sanctioned the policies. There is a blatant conflict of interest here.
The Plan should be the most appropriate strategy when considered against reasonable alternatives, based on a proportionate, robust and credible evidence base. There is NO reasonable alternative offered. 9,000 houses in a rural aspect is clearly not proportionate. The financials are far from robust (discussed elsewhere) and the evidence base is not credible. The Housing Assessment is based on a series of falsehoods. The use of historical data is overplayed and there is no provision for the falling population once the 'baby boomer' generation start to diminish which is in scope of this plan. This assessment needs to be revisited urgently with local input (only 17% local provision is shocking) and the numbers suggested need to fall significantly if this plan to reach the desired levels of local acceptance mandated by the European model of Master planning.
This plan is not effective. The infrastructure offered is insufficient to protect existing communities. There are no guarantees of infrastructure provision - this is exceptionally worrying. Especially given the parlous state of local hospital provision as evidenced via the national media. Colchester should not pay the price for being prepared to accept massive over-development over the last 20 years when many other areas of the country have simply ignored the issue.
Specific policies in the Framework or the Plan that indicate that development should be restricted.
Firstly, this is subjective. No part of the policies states the volume or change of character of this rural area.
Statement of Community involvement - This has not been not met at all. There is a disappointing and ultimately worrying lack of engagement on all key issues other than the prerogative to continually increase numbers in direct contradiction to all the efforts of those towns and villages about to be subsumed by this unwarranted over-development.
This is not justified as there is no measure pf appropriateness as no other option has been tendered. Other sites include Rowhedge, Clacton, to the north of Longbridge - (originally in scope for this plan), Middlewick Ranges and to the north of the A120. None of these have been considered. It is not justifiable, (nor sustainable) to build on Grade A rated farmland. It is not acceptable to exiting communities that the Issues and Options iteration of this plan contained ZERO options. The tacit acceptance by this scheme that it will 'go there' is deeply unpalatable.
Distinct Settlement Boundary - Wivenhoe is classified as such by the local plan. It is mystifying how building 480 yards on such a scale can be considered as protecting this status.

See the attached Letter

Further development around the area of should not go ahead. the recent development at Stanway has already caused regular traffic tailbacks on the old London Road all the way back to the Stanway Garden Centre and the new house building has hardly begun.
The infrastructure in and around Marks Tey is struggling with the usage that it has to cater for. The A120 and A12 which are expected to be used by those in the development areas are often already congested and can not be expected to cater for the traffic generated from any new developments.
The slip road from the A12, south bound, to the Eight Ash Green turn off is very short and extremely dangerous at peak times. The traffic queuing to come off the A12 is often stationary on the A12 for a hundred metres or more.
With the increase in traffic there will be -
- Increased traffic jams
- Increasing pollution (fumes and noise)
- Greater wear and tear on the road surfaces which the A12 at Marks Tey is in dire need of re-surfacing.

I have no doubt that any housing built will be purchased. As part of the steering group for Marks Tey Neighbourhood Plan I recently asked 3 different Estate Agents the question Who is buying the houses being built at the moment in the Colchester area, 40 - 50% are purchased by those outside the area, the single biggest influx is from the East side of London. If you have 2 bedroom houses selling for in excess of £150k and 3 bedroom houses selling for in excess £250k, such as in the present developments in Stanway and Marks Tey, people/families only working in Colchester on typical Colchester wages are unlikely to be able to purchase. For the majority of purchases one or more in a household will likely work in London where wages are much higher (x3 more for many similar positions). This leads to issues on travelling to London.

At present the most people will take the train into London rather than driving into the city due to congestion on the A12 (the only viable road route) and parking once you are into the City. As a commuter I find the train service terrible with regular over crowded trains, trains needing repairs, regular delays and a very expensive fare (one of the highest per mile in the country). Taking a very conservative estimate that a third of the houses will have 1 train commuter, there would need to be another 9 trains in the morning and another 9 trains in the evening to cater for the extra people.
There are also the less obvious issues that go with a large amount of extra housing or businesses for any area. East Anglia is one of the driest areas of the country with rainfall per capita less than the Sarah desert. Water consumption and sewage treatment must be considered, would the existing sewage treatment and water plants in the area, such as in Copford, be able to cope with the excess demands.
Large scale development will also put the local supply of electricity under pressure.

Medical services in and around Colchester have been in the spotlight in recent years for failing to meet standards expected. It is vital that support is given to those in the local NHS that are striving so hard to provide a world class service that we all wish for. To add such a large number of people to the area extra services will be required such as extra GP and Dental clinics and for extra funding and physical expansion of the local hospitals in Colchester and Braintree. This extra funding and expansion must occur prior to any development being completed, after all deficiencies in the local medical services will impact on patient health and risk lives. A heart attack patient can hardly be expected to defer an attack while A&E service capacity is increased. No housing development warrants risking lives.

Pollution levels are very high in the Marks Tey area, both air pollution due to the A120 and A12 and the noise levels from the roads.

The inclusion of a Garden Community at Marks Tey of circa 20,000 homes is ill conceived with none of the concerns raised in early consultations answered i.e.
1. The GC at Marks Tey is in the wrong place for a new town.
2. trunk roads that are already congested and are highly polluting and have dangerous poor air quality.
3. Station is poorly placed with trains already full.
4. No meaningful public transport planned until 2030.
5. Jobs will be difficult to provide - the councils own consultants cite these difficulties.
6. As it stands, the development of a GC at Marks Tey will be nothing more than a commuter town given the current plans.
7. 3200 acres of top grade agricultural land to be given over to a commuter town - does not seem a grade deal for the locals at Marks Tey or the Colchester area.

I totally object to the middlewick ranges development. This is a fantastic green space with an abundance of wildlife. This would all be destroyed along with green space for our children and future generations to enjoy.
The housing quota for Colchester has already been met. Therefore this is a totally unnecessary development that will serve. I benefit whatsoever to the people of colchester. Who are already suffering from an abundance of new homes and a severe lack of infrastructure in the town.

We find that the Plan is unsound. It is neither justified, effective, positively prepared or. Please find our full response here:
http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSE-2017-Part-1-Consultation-response.pdf

Support is extended for the presumption in favour of sustainable development and the Local Plan's approach towards considering development proposals. This accords with the National Planning Policy Framework (NPPF) (2012).

Support is extended for the presumption in favour of sustainable development and the Local Plan's approach towards considering development proposals. This accords with the National Planning Policy Framework (NPPF) (2012).

Policy SP1 - Presumption in Favour of Sustainable Development

It is commonly accepted that human activity, founded on growth based economic strategies and consumerism, is now exceeding the planet's carrying capacity in terms of natural resources and biodiversity. Simply put we are using up natural resources faster than they can be replaced and creating waste and pollution faster than it can be absorbed naturally. In 2014 the UN General Assembly's working group on Sustainable Development set out 17 Sustainability Goals. This assessment of Sustainability Goals is accepted as a sensible template for action as it was widely consulted and has benefited from many contributors worldwide. It shows how development will have a sustainability impact locally as well as globally. In 2000 the United Nations Secretary-General Kofi Annan initiated the Millennium Ecosystem Assessment [MEA] which was tasked to assess the impact humans have had on the environment; the results were published in 2005. Its key finding was that:

"Over the past 50 years humans had changed ecosystems more rapidly and extensively than in any comparable period of time in human history, largely to meet rapidly growing demands for food, fresh water, timber, fibre and fuel. This has resulted in a substantial and largely irreversible loss in the diversity of life on earth".

Policy SP1 correctly reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. However, given the findings of the MEA future development will clearly need to be significantly different from what has gone before otherwise we will simply continue the trend of moving away from sustainability rather than towards it. Site analysis and appraisal of options for the three Garden Communities has been undertaken. However further steps are required which need to be identified within the Strategic Plan. Firstly, sustainability assessment needs to continue as an iterative part of the design process. Secondly, the urban designs need to be fully evaluated in a neighbourhood context at the planning application stage and lastly post development examination of actual results should be undertaken to confirm the quality of outcomes and to inform procedure for future development.

Although garden community proposals tend, in theory, to be in accordance with sustainable development objectives, we do not consider the scale, location and potential impact of the three proposed such developments to meet these requirements and therefore question the overall soundness of the Plan.

The presumption in favour of sustainable development needs to make it clear that infrastructure must be considered first. If development is to be sustainable the planning committee should be required to consider the infrastructure implications of an approval and to seek s106 or CIL contributions where appropriate.

I support CAUSE's representation.

Whilst this is largely a reproduction of the relevant policy text in the NPPF, we note that paragraphs 1.36 and 1.37 are inappropriately casted. Paragraph 1.36 is written on the basis that there are "no policies relevant to (note the typographical error here) the application or relevant policies are out of date...", yet in the following paragraph at
1.37 the decision maker is asked to have regard to "...the Plan..." in terms of whether it "indicates that development should be restricted". This is clearly a non sequitur and should be amended in order to be consistent with National Policy.

Further to the Section 1 and Section 2 Local Plan consultations of the North Essex Authorities, Officers have considered Colchester Borough Council's Local Plan proposals and the Leader of the Council has agreed that TDC makes the following submission:
Having regard to the Duty to Cooperate, Tendring District Council (TDC) has worked closely with Colchester Borough Council (CBC) in the preparation of their joint (including Braintree District Council) and individual Local Plans.
In response to the joint public consultation for the Submission Plan stage, TDC has reviewed the Colchester Borough proposals with particular regard to those aspects most likely to affect Tendring District residents, businesses and visitors and offers general support for its policies and proposals.
Transportation is a key issue for Tendring District's residents, businesses and visitors, with the most heavily used routes (road and rail) providing access to and from the District being from the west, at Colchester. TDC welcomes CBC's commitment to continued partnership working with the North Essex Authorities, government departments, statutory agencies and other partners to better integrate all forms of transport and improvements to infrastructure.
TDC welcomes CBC's proposed policy measures to improve road, rail, bus, cycle and pedestrian infrastructure in East Colchester, bordering onto Tendring District. In particular, the potential for future developments in the area to provide the opportunity and demand for a rapid transport system is recognised in the context of the Garden Community and Knowledge Gateway proposals.
TDC welcomes CBC's acknowledgement of the District's diverse economy and acknowledges that for the Manningtree area - including Lawford and Mistley, its relative close proximity to Colchester and relatively good transport links to London are important locational considerations for many residents.
Although Tendring District is seeking to promote the vitality and viability of its own main town centre of Clacton-on-Sea, the Council recognises that the size and proximity of Colchester will, in practice, mean that many of Tendring residents will continue to rely upon Colchester for relatively easy access to larger shopping facilities and other services, which exist due to Colchester's greater local population size. In this context, the Council supports Colchester's aim to retain its own vitality and viability, which will help to ensure that Tendring District's residents do not necessarily have to travel further afield; to Ipswich or Chelmsford, for example.
On a similar basis, TDC welcomes CBC's support for the protection and provision of sports and recreation facilities, some of which do not exist - and would not be viable - within Tendring District and therefore also serve Tendring District residents.
TDC also welcomes CBC's commitment to ensuring that growth is sustainable, helping to address the causes and effects of climate change and protecting the natural environment, including ensuring that new developments would not have significant adverse effects upon designated sites within Tendring District.
TDC is committed to continue its partnership working with CBC and BDC to produce a Strategic Growth Development Plan Document for the Tendring/Colchester Borders Garden Community and Recreational Avoidance and Mitigation Strategy, to positively address any other cross-border issues

1. Introduction

1.1. Andrew Granger & Co. Ltd specialises in the promotion of strategic land for residential development, commercial and employment uses through the Local Plan process.

1.2. On behalf of the Trustees of the S A Meller Estate we are seeking to work with Colchester Borough Council in promoting Land at Place Farm, Rowhedge Road, Colchester (Appendix
1) for residential and employment development uses.

1.3. This document provides a written submission to the Colchester Borough Local Plan 2017- 2033 Publication Draft Consultation and is framed in the context of the requirement for the Local Plan to be considered legally compliant and sound. The tests of soundness are set out at Paragraph 182 of the National Planning Policy Framework [NPPF], which state that for a development plan to be considered sound it must be:

- Positively prepared - the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

- Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

- Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

- Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

1.4. This submission supports the proposed allocations at Land at Place Farm, Rowhedge Road, Colchester for employment and residential uses as identified in the Proposals Plan and also promotes additional adjacent land for residential development.




















P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 4

2. Site Appraisal & Context

2.1. The proposed development site has a total site area of approximately 5.97 ha (14.7 acres) and is located on the south-eastern edge of Colchester and accessed off Rowhedge Road, as shown outlined in red in Appendix 1.

2.2. The site consists of a single field of pasture land with clearly defined boundaries marked by mature hedgerow to the north, south, east and west. The site is bordered to the north and east by the Whitehall Industrial Estate (including the Colchester Sewerage Treatment Works), to the west by residential properties and to the south by further agricultural land.

2.3. The site is located in close proximity to a number of services and amenities, which are located approximately 0.4 miles from the site entrance on Old Heath Road which is identified as a Local Centre in the Plan. Services include Old Heath Congregational Chapel, Old Heath Community Primary School, Co-Op Food Store and a number of small, independent coffee shops and retailers. The Whitehall Industrial Estate, which is located adjacent to the proposed development site, also provides a number of employment opportunities. Businesses located at the estate include Gallery Bathrooms, Nash Bathrooms, Maple Tree Cars and Colchester Dairy.

2.4. There are further services and employment opportunities available in close proximity to the site in Colchester Town Centre (approx. 1.9 miles), Rowhedge (approx. 1.2 miles), Fingringhoe (approx. 2.1 miles), Wivenhoe (approx. 2.3 miles) and Abberton (approx. 3.7 miles).

2.5. In addition, the site is well served in respect of public transport links with the nearest bus stop located next to the site entrance on Rowhedge Road. This stop is served by the 66(A/B) bus service which runs between West Bergholt and Rowhedge via Colchester with services stopping at Rowhedge Road approximately once an hour between 7am and 7pm from Monday to Saturday.

2.6. We consider that the site has the capacity to accommodate a mix of residential and employment land uses, as follows:

2.6.1. It is considered that the allocated site, identified red on the Proposals Plan and blocked red at Appendix 2, and the adjacent land (blocked green at Appendix 2) could facilitate the development of approximately 100 dwellings including pedestrian links, public open space, car parking, landscaping and drainage. Any proposed development scheme would provide a range of property types and sizes, including a proportion of affordable housing, subject to viability.

2.6.2. The site also has the capacity to accommodate approximately 2.3 ha of employment land (shown blocked purple at Appendix 2), which could provide up to 9,200 square metres of new floor space, associated car parking, facilities and landscaping, which would complement the existing Use Class B employment land uses at Whitehall Industrial Estate.



P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 5

2.7. Any development of the site could be sensitively designed to protect the residential amenity of the neighbouring residents to the west of the site, by retaining the existing hedgerows and matures trees around the site boundary, and enhancing those boundaries with significant additional planting. Furthermore, any development scheme would give consideration to balancing the demands of the proposed residential land use in comparison to the existing and proposed employment land uses; to ensure that all land users enjoy an appropriate level of amenity.

2.8. Therefore, we consider the site to be in a sustainable location, close to a number of services and facilities and highly accessible. It provides a good opportunity to make a valuable contribution towards meeting the Borough's development needs.













































P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 6

3. Comments on the Colchester Local Plan Publication Draft Document
3.1. On behalf of the Trustees of the S A Meller Estate we wish to make the following observations on the Colchester Local Plan Publication Draft Consultation. Overall, we agree with the vision and objectives set out in the Draft Local Plan, however, to ensure that the plan is robust and provides for flexibility, we make the following comments.

Section 1: Shared Strategic Plan

3.2. In respect of Policy SP1: Presumption in Favour of Sustainable Development, we strongly support the inclusion of this policy in the Colchester Local Plan in line with Paragraph 14 of the National Planning Policy Framework [NPPF]. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of Colchester and North Essex.

3.3. We support the proposed spatial strategy for growth set out in Policy SP2: Spatial Strategy for North Essex. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are accessible and are within close proximity to a wide range of employment opportunities and local services and facilities.

3.4. With regards to Policy SP3: Meeting Housing Needs, we fully support the flexibility provided by the recognition that the development requirements outlined in this policy are a minimum and the positive approach to development proposals outside of the Local Plan allocations, where they support the overall spatial strategy. We consider that the land at Place Farm, Rowhedge Road has sufficient capacity to deliver up to 30 dwellings, which would provide a range of dwelling types and sizes and contribute towards meeting the identified housing needs for the Colchester Borough.

3.5. We fully support the flexible approach to employment and retail development shown in Policy SP4: Providing Employment and Retail. In particular, we support the flexibility demonstrated in relation to the quantum of development across the plan period through the use of baseline and higher growth scenarios. However, in order to ensure the plan has a robust approach towards the provision of employment and retail land, we believe that it is important for the policy to clarify that the baseline development levels are a minimum requirement. This will ensure that the Borough provides the level of employment and retail development that is necessary to deliver the jobs required to sustain the anticipated population growth. As previously stated, we consider that the land at Place Farm, Rowhedge Road has sufficient capacity to deliver up to 2.3 ha of employment land which would contribute towards meeting the identified needs for the Colchester Borough.

3.6. In respect of Policy SP6: Place Shaping Principles we fully support the recognition that good planning and good design are inseparable in line with Paragraph 56 of the NPPF. The proposed development scheme for the subject site could be designed with consideration



P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 7

for all of the criteria contained within the policy; the proposed development site could be designed in a manner that respects local character and context and ensures that it enhances the quality of the street scene, any scheme would seek to retain a significant proportion of the trees and hedgerows that bound the site and a large amount of additional planting could also be provided to ensure that the residential amenity of neighbouring properties to the west and future residents of the site is not adversely impacted. Furthermore, sufficient space would be provided on-site to allow for off-street car parking for all proposed dwellings.

Officer NB: Extract in relation to SP7-

The level of retail or other supporting floor space is not rehearsed in either Section 8 or in Policy SP7 and this needs to be addressed, as does their potential impact on surrounding town centres if they are to fulfill a role anything beyond consuming only that expenditure of the residents of the new settlements. Even if this is the anticipated outcome, we would urge caution that residents are still likely to spend a significant percentage of their comparison / non food income at higher order centres, such as Colchester Town centre, and as a consequence it is vital that any additional retail floor space at these locations is not overstated.

We look forward to discussing this matter with the Council in greater detail.

End of Extract
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Cushman and Wakefield act on behalf of CBREGI and have been asked to respond the Council's Publication Draft Local Plan (June 2017); representations for which are due by 11th August 2017.

CBREGI are key stakeholders and manage significant assets within Colchester Town Centre, which include:

* Lion Walk Shopping Centre;
* Red Lion Yard; and
* The Odeon Cinema and attached restaurant units

CBREGI have also been working jointly with Sovereign Centros and Colchester Borough Council to bring forward Vineyard Gate, the key town centre development site in Colchester, for a mixed use retail-led development.

We support overall Colchester Borough Council in its aspiration for Colchester Town Centre. Notably, we support the Council in seeking to maintain Colchester as the key retail destination within the area, to protect and enhance its vitality and viability and as the key location to meet the needs of current and future generations in Colchester's diverse and growing borough.

We also support the assertion of Colchester town centre as the key retail destination, not only for Colchester as the major settlement in the district, but also for the Colchester / Braintree / Tendring Districts. We agree it is important that the town centre continues to act as the apex attractor for new town centre uses.

Strategic Objectives

The Plan, at page16, sets out some strategic objectives for the wider strategic area, including Braintree and Tendring Boroughs. It is our view, given the importance of the principal Town Centres in this wider area, and particularly the importance of Colchester Town Centre as the apex location, that a strategic objective for a strong, vital and viable Colchester Town Centre should be included with the Plan's strategic priorities.

We note some of this is rehearsed in the Strategic Objectives (Section 11) in Part 2 of the Plan, but we consider that this issue is sufficiently important to have this rehearsed also in Part 1 Strategic Objectives.

Policy SP1 - Presumption in Favour of Sustainable Development

The approach to the presumption in favour of sustainable development is that set out in the NPPF. However, we consider the council should make clear in the preceding paragraph to SP1 (ie para 2.1) that in accordance with S38(6) of the Act, and the guidance of the NPPF, that development decision should be carried out in accordance with the development plan, unless there are material considerations to indicate otherwise. One such consideration is the presumption in favour of sustainable development, which is rehearsed in SP1.

Policy SP4 - Providing for Employment and Retail

We note that Policy SP$ seeks to identify base positions for identifying the need to provide for employment and Retail, However all of the statistics / requirements relate principally to 'B' Class uses. We suggest that the Policy / supporting paragraphs are extended to include anticipated retail growth or that retail is deleted from this Policy heading and dealt with elsewhere.

Section 6 - Infrastructure and Connectivity

We welcome the Council's position in seeking to align development with accessible locations, alongside promoting greater use of alternatives to the private car. However this section does not mention Colchester Town Centre as being a highly accessible location, nor as a preferred location for development given its high accessibility index and this should be addressed.

Section 8 - Cross Boundary Garden Communities / Policy SP7

Whilst we appreciate that there is ongoing work on the nature and form of the proposed garden communities, it is not clear from the local plan, nor indeed Policy SP7, of the supporting non residential infrastructure which will be considered appropriate as part of the wider delivery of new homes. It is reasonable to presume that these garden communities, in providing a 'holistically and comprehensively planned new community' will involve the provision of ancillary facilities, including retail and leisure uses alongside food and drink development. Whilst there is mention of supporting mixes of uses in district centre / local centres, no further guidance is given.

The level of retail or other supporting floor space is not rehearsed in either Section 8 or in Policy SP7 and this needs to be addressed, as does their potential impact on surrounding town centres if they are to fulfill a role anything beyond consuming only that expenditure of the residents of the new settlements. Even if this is the anticipated outcome, we would urge caution that residents are still likely to spend a significant percentage of their comparison / non food income at higher order centres, such as Colchester Town centre, and as a consequence it is vital that any additional retail floor space at these locations is not overstated.

We look forward to discussing this matter with the Council in greater detail.




10.1 Key Diagram (Section One Maps)

We consider it would not be unreasonable to identify the existing key town centres, including Colchester, on this diagram.


Section 2: Vision

We support the reference to Colchester Town Centre and the importance of ensuring its continued vitality and viability within the Section 2 Vision. For the reasons set out above we additionally consider this should form a key objective in Part 1 of the Plan.

Policy SG1 - Colchester Spatial Strategy

We support the spatial hierarchy approach which focuses growth on the urban area of Colchester, reflecting its position as the main location for jobs, housing, services, and transport.

We also support an emphasis that the Central Area of Colchester, notably (rather than just including) the Town Centre, as the most sustainable location for new development given that it can accommodate higher densities and achieve good access to public transport and a further concentrated mix of uses which will promote linked trips and further minimise the need to travel.

Retailing: Centres Hierarchy (paras 12.42 et seq) and Policy SG5 / SG5a

We support the Council's approach to defining a Centre Hierarchy, which identifies Colchester Town Centre at the top of that hierarchy, followed by District and Local Centres; in accordance with the recommendations of the 2016 Retail and Town Centre Study.

This, in our view, helps to establish the Local Planning Authority's overarching strategy for the growth and management of town centre uses and should seek to influence a 'plan -led' approach to bringing forward new development in terms of type and scale.

We also support the Council using this when planning applications are submitted in a decision taking role, in accordance with the Plan and having regard for the primary role and function of that centre within the hierarchy.

Policy SG6 and supporting Table SG6a: Retail impact and Impact Thresholds

We support the Council's approach in SG6 that proposals for new town centre uses that are not within a defined centre and are not in accordance with the Local Plan (including proposals for a change or intensification of use, or variation of a planning condition), will need to demonstrate that a sequential approach has been undertaken to site selection and that there should be additional impact tests applied above a locally defined threshold.

However, it is wholly inappropriate to require an impact assessment within Colchester Town Centre for those schemes above 2,500sqm gross comparison goods or 1,500sqm gross convenience and leisure services, given the Council's ambition to foster Colchester as a pre-eminent location for new town centre related development.

We request therefore the removal of the floor space thresholds in table SG6a in relation to Colchester Town Centre.

Policy TC1 and TC2: Town Centre Policy

We support the Council in confirming the pre-eminent position of Colchester within the area and the key location for new town centre related development.

Policy TC3: Vineyard Gate

CBREGI and Sovereign Centros have been working alongside the council to bring forward Vineyard Gate, as the key development option within the Town Centre.

We therefore support the recognition of the importance of this allocation within Colchester Town Centre; as the immediate priority to help sustain and enhance the town centre as a whole.

Policy NC1: North Colchester and Severalls Strategic Employment Area

We maintain our objection to the proposed multiplex cinema element for the proposals at Northern Gateway, given the significant adverse impact this will have on the Odeon Cinema within the town centre.

Whilst the Plan does not explicitly mention the proposition of a multiplex as part of NC1, instead referring to the area as a 'leisure / community hub', it is clear from the proposals advanced through planning applications have the intention for this to include a multiplex cinema.

Policy WC2: Stanway

We note the Council's proposed allocation of the land between Tollgate West and London Road (the former Sainsbury's Site) at Tollgate for residential development, which we support. This appears a sensible solution to the re-use of this site and will deliver valuable housing development which will further consolidate the role and function of Tollgate to its surrounding residents.

Elsewhere in the Plan, we support the Council's intention to control retail development within the Tollgate Area in order to maintain the role and vitality and viability of Colchester Town Centre.


Conclusion

Overall, we support the approach adopted in the Colchester Local Plan: Publication Draft June 2017 to further protect and enhance the vitality and viability of Colchester Town Centre and in seeking to ensure that development of key sites within Colchester town centre are prioritized above other locations.

We maintain our objection to Northern Gateway and Tollgate for additional town centre uses, and support the Council's suggestion that the former Sainsbury's site at Tollgate is allocated for residential development.

see attached statement

see attached form