Policy SP2: Spatial Strategy for North Essex

I understand that previous representations regarding West Tey proposed housing development are to be ignored and new representations or comments are required. I think that this is a bit like ignoring a National Referendum and demanding another as the results of the previous referendum are not valid. An interesting precedent? However, I repeat my previous comments below although worded slightly differently.
First of all I have to say that I fully support the CAUSE campaign and have put my name to their representations although I do have some additional comments and questions as under.
1. Summary
There seems to be a lack of overall leadership and responsibility when considering the cumulative impact on local infrastructure, environment and actual needs of each individual 'neighbourhood plan' and new towns proposed within the East Anglia region. It seems to me to be adding up to a total disaster at so many levels all of which can be avoided and solve most of our housing shortage with a more considered long term approach to planning. There should be named individuals with better central and local responsibility for taking an overview of the real and genuine concerns and objections of local residents.
2. Lack of 'joined up' planning
This is SERIOUS concern. Each local village, town etc. are being asked to comment on proposed relatively small but locally devastating housing developments of up to several hundred houses in each locality. There are objections to each of these housing projects as few of these villages and towns individually have sufficiently spare infrastructure capacity to handle the additional homes although most will have some limited spare capacity for developments much smaller than the original proposals. But no one seems to be taking ownership of the impact of each of these developments across the whole of the region and adjoining regions and the cumulative impact that these thousands of extra houses will have on the existing infrastructure across East Anglia and east London. Each new development should take into account what the residents are likely to do for jobs, where the jobs are located and how they are going to get there.
When adding to this the proposed mega new towns at West Tey and other parts of this County and all proposed developments in adjoining Counties a picture will surely emerge of an entire infrastructure including roads, rail and buses, schools, medical and emergency facilities etc. that just will not cope. They struggle to cope with the current population level. Particularly for my locality (Kelvedon) both the A12 and A120 will have to be significantly upgraded to get even close to coping with the increased traffic, with direct road links between Tiptree and the A120 via Coggeshall and a new junction on the A12. The living environment will become intolerable for those unfortunate enough to live in this region.
Considering and commenting on each proposed new town development and each 'neighbourhood plan' in isolation risks getting it all wrong at so many levels. Who is in overall charge?
3. The railway
I am aware that cash has been promised for the much needed upgrades to the rail track into London which should improve overall reliability. The questions are -
A) How many extra passengers are predicted to travel into London Liverpool Street from across Essex, Suffolk, Norfolk, Hertfordshire and Cambridgeshire following all new housing builds in these Counties?
B) Will this mean a requirement for additional trains arriving at Liverpool Street between 7.45am and 8.45am? If so, how many?
C) Can these additional trains navigate the bottle neck just outside of Liverpool Street Station even with the track upgrades during this critical one hour period?
D) Most proposed new housing will not be within walking distance of stations. How will the access roads and car parking facilities cope?
E) Is a new station planned for West Tey?
4. Loss of agricultural land
One of the many criteria for a country to secure its economic future is to not be dependent upon imports to feed its population. This means all of our agriculture land MUST be retained for farming using long term sustainable methods to provide more than sufficient and reasonably priced food for our population now and for many generations into the future. We should never be reliant on a high value pound to keep food costs down and we should never be reliant on imported food to keep us well fed. The global population has considerably more than tripled since I was born 70 years ago and with this increasing population pressures and climate change currently causing all kinds of problems, it could only be a matter of time before there will be little spare food globally for countries to export as they will need it all for themselves.
Will this happen? Who knows, but dare we take the risk?
5. We need more housing - there is a shortage
Certainly we need more investment in housing - social, retirement (social and private) and private houses from low cost through to executive. There is currently a chronic shortage at all levels. Preparing for post Brexit, it becomes even more important for investment in British businesses and innovation. New housing and new business investment along with improved and co-ordinated infrastructure really should go together in a single long term plan.
Not every worker commutes or is prepared to commute and investment in job creating businesses and housing should always be together and in close proximity. Ideally, such investment should be on reclaimed brown field sites and NEVER on green field or agricultural land. This investment should be evenly spread across the UK and not just focussed into the South East. Investment in redundant brown field areas should include investment in modern industrial and commercial use properties and businesses as appropriate for skills, needs (including available workforce and local housing shortage) and size of the available land in that region. Houses should be built close to where there is available work and with a modern and integrated infrastructure to support both the businesses and the housing - all part of the essential criteria to help secure this country's economic future.
How does all of this fit with the West Tey project? Do we actually need all this extra housing in this region?
At a meeting that I attended on our local 'Neighbourhood Plan' someone suggested that if every parish in the country increased the total number of houses within the parish boundary by just a couple of percent, there will not be a housing shortage and the local infrastructure will not noticeably suffer. Seems a plan to me although, as I said, new housing and new business investment should go together along with infrastructure investment to support both local business and the population needs where it is most needed and where it is most viable.


My apologies for going on a bit with these comments and even going away from the very limited scope for comments in this forum but I feel most strongly that we do need a properly joined up and co-ordinated plan for our future housing, infrastructure and economic needs across the whole of the East Anglia region and the whole of the UK. Asking people to comment strictly on single local planned developments fails in so many areas and one wonders if this is deliberate. There is much money to be made from each of these individual plans should they go ahead and, as such, pressure will be applied for them to go ahead regardless of the overall impact on the local population and regardless of actual local needs and also national needs in the longer term. Hopefully, our local politicians will take an honest and long term approach when deciding on these plans and take an overview of the impact of ALL building projects in the whole East Anglia and east London area.

Insufficient proposals for Infrastructure upgrades
Road, Rail, NHS, Assumption seems to be based on changing peoples travel habits which won't work unless services are improved before development. Particular attention to traffic black spots required as stationary traffic causes the most pollution and this has not been addressed by the plan

The University of Essex supports the overarching spatial strategy as set out in this Section and in Policy SP2.

4.18 Generally the NHS policy locally is to attempt to accommodate growth wherever possible within current premises envelope, though this is likely to require capital works to adapt facilities over time, and only to seek new premises where this is demonstrably necessary.
4.19 It is not possible to accurately determine the build cost or size of new health facilities at this stage. This will depend on a large number of complex and inter-related factors that can only be resolved at a more advanced stage in the planning process. It will not be the case that each new health facility would be a fixed size or would have a fixed range of services.
4.20 Clinically there are circumstances where co location of GP and other NHS or social care functions are desirable and would be considered or sought.
4.21 The West of Colchester Garden Community will add significantly to the number of patients within the catchment area. The location of existing facilities mean that it is unlikely that their expansion would address the needs over the plan period. Therefore a new facility is likely to be required.
4.22 The East of Colchester Garden Community will add significantly to the number of patients within the catchment area. The location of existing facilities mean that it is unlikely that their expansion would address the needs over the plan period. Therefore a new facility is likely to be required.

My comments should be read in conjunction with detailed replies that have been submitted by CAUSE and SERCLE who represent the community in which I live ( Bardfield Saling) and Essex region in which I have lived since 1988 and prior. These comments consider the wider issues of the development of North Essex. I agree with CAUSE and SERCLE's detailed arguments which cover aspects of consultation from environment to financial. I am outlining my views under spatial strategy as this covers the wider view of your plans. As a council tax payer in Essex since 1988 I am horrified at both the potential environment and financial carnage that could ensue.

There has been no attempt to present the vision by Essex County Council and the associated district councils to effectively urbanise North Essex in the long term ie beyond 2033 in the medium term and into the long term. The collective plans include three or more ' garden settlements' that each have a scale comparable to an urban environment like Braintree across the region from Stansted Airport to beyond Colchester. This vision if realised will transform the region into an urban one. There has been no attempt as far as I am aware to join up ECC and the DC's respective schemes and present them as a whole to the public and your electorate. In my own mind I have attempted this and the outcome is a chilling one. This stems largely from the reality that the transport structure is currently woefully inadequate and this is in part reflected in current consultations regarding A12 upgrade and a new route for the A120 to be dualled between Braintree and the A12. Yet the consultation documents talk about the North Essex region enjoying excellent links to London and the wider region. Maybe once these fundamental improvements are realised.

Essex is littered with relics of the absence of coherent strategy in respect of road& rail. These are some examples that spring to mind and thus endorse the absence of the council(s) ability to deliver coherent infrastructure solutions.

Army and Navy flyover - a 1970s temporary solution and still limping on to this day.

A swathe of 6 lane highway at Springfield underneath the A130 route between the A131 and the A12 that is congested appallingly alongside a mushrooming Beaulieu Park . Chelmsford North Station- talked about decades ago - not built.

Cressing loop on Braintree to Witham branch line, anticipated to increase capacity. Talked about for decades - not realised. And now we have AECOM in conjunction with BDC planning its evolution into a rapid transit facility connecting miraculously through Braintree via Springwood Industrial Estate to WOB. Are you serious ? Will the long suffering 100,000 users per year be consulted ? Are Network Rail and the rail franchise holders on the same page as AECOM and BDC ? Whilst on the subject of transport connectivity for Braintree, the scope for a link to Stansted Airport was corrupted in about 1992 when UDC and presumably ECC agreed to the construction of the Raddison hotel at Stansted in the route of a potential future rail extension beyond Stansted towards Dunmow and Braintree. If realised this could have helped unlock the future value uplift that your 'garden' model seeks to achieve over the long term. I would refer you also to comments from ID61497 - Mr Bigg Braintree and Witham rail users in the BDC consultation. The case for rail acting as the catalyst for value uplift is well proven. A 2004 plan for a west of Braintree eco town showed a line on a map joining Braintree to Stansted by rail. The populous of this largely rural area has been daunted since then with imminent mineral extraction now also thrown into the mix.

Galleys Corner roundabout at Braintree - the size of a dinner plate on a strategic route. Brilliant! And now more public money to correct the fundamental error in the same way as the errors in design of south Essex Fowlers Farm was eventually resolved, And in the meantime numerous £1million paint pot solutions to help us on our way. There is no credibility through any of these examples. My grave concern is that the scale of the carnage will go to as yet unseen levels.

Considering now the brownfield element of prospective land usage there is a worrying lack of detailed inclusion of sites and their detailed relevance or not,. This is what is expected by many local commentators on your plans. My area includes Andrews Airfield, a busy important facility that will be destroyed without rational consideration of its loss. It is not a brownfield site. Brownfield sites in my locality might include Chapel Hill industry site in Braintree - a nightmare for any HGV driver let alone local residents. Oh, and this site is all but adjacent to the prior mentioned Braintree -Witham rail line and surely a candidate for well designed urban housing at an appropriate density. Former Crittall manufacturing at SilverEnd. Silver End of course originally developed on garden principles with philanthropy at its core. How different it seems from the premature incorporation of North Essex Garden Communities Ltd with its board of councillors. How can public money be spent in this way ahead of full consultation and the inspectors report? At best it reeks of cronyism, scope for conflict of interest, and at worst risks of corruption. Curiously UDC seems absent from all of this despite Stansted airport being quoted through the consultations as a key employer and engine of growth. But I forgot, sorry, UDC/ECC approved the building of the Raddison hotel in the way of the railway that is part of a key transport hub in the area. Woops.

In a post BREXIT world the region without doubt needs to evolve, develop and resolve its inherent weaknesses to enable it to attract and retain economic investment. But the economic risks and transfer of debt to the public purse is potentially terrifying particularly for Braintree district unconnected as it is yet to either the wider region or genuine potential through say the knowledge gateway and Essex University. Yet why not develop Braintree and other urban districts holistically on genuine garden principles ? Fix the problems, develop the dodgy brownfield sites, aim to achieve the objective of resolving the local housing problems on the way towards making the areas attractive for people and investors. Garden settlements like WOB in the middle of now-where? How on earth can that be a solution other than for more out-commuters prepared to trade out of houses with overheated values closer to the metropolis.

As it stands the obfuscated vision of ECC and its DCs, their combined absence to present the truth in an understandable way to the general public is at the core of my argument for objection to your spatial strategy. But be warned, the public are not stupid and will hold those elected to be accountable.

(A) Policy SP2 - Spatial Strategy for North Essex

This policy includes the sentences..
Three new garden communities will be developed and delivered as part of the sustainable strategy for growth at the locations shown on Map 3.3 below and the Proposals Map. These new communities will provide strategic locations for at least 7,500 additional homes within the Plan period in North Essex.

However none of the Publication Draft Local Plan documents includes a Map 3.3 nor is there a map labelled as the "Proposals Map" in the common Section 1. As far as can be ascertained these maps are not in any part of the Publication draft Local Plans.

(D) Different Garden Community maps at different scales are included in Section 1 of the Publication Draft Local Plans, which are stated as being the same for Braintree, Colchester and Tendring

Although Section 1 is stated as being the same between all three Councils, different maps are presented at different scales. The maps have no keys.

(i)Section 1 of the Braintree Local Plan includes 5 maps relating to the proposed Garden Communities - however three of the maps are "half-maps" which stop at the district / borough border so the full extent of the proposed garden community is not presented. The maps are also at different scales.

(ii) Section 1 of the Colchester Local Plan only includes one "overview" map.

(iii) Section 1 of the Tendring Local Plan includes NO maps. A half-map of the Colchester-Tendring borders garden community is in the "local maps" appendix.

(i) Braintree Publication Draft Local Plan: Section 1
Chapter 10 Appendices & Maps, page 66, includes 5 maps - 4 of which are reproduced below:

(page 66) Map 10.1 Garden Communities- see attached: an overview map with the 3 proposed garden communities shown as orange circles / lozenges.

(page 67) Map 10.2. A - West of Braintree (1:20,000) - see attached: a purple shaded "half-map" showing the part in Braintree District. The purple shading stops at a solid black line - which is taken to be the Braintree-Uttlesford border (no map key). The extent to which the proposed garden community might / would extend westwards into Uttlesford District is not shown. The purple shaded area on this map seems somewhat at variance with the orange circle on Map 10.1 which did not extend across the Braintree / Uttlesford border.

(page 68) Map 10.3. B - Colchester / Braintree borders (1:20,000) - see attached: a purple shaded "half-map" showing the part in Braintree District. The purple shading stops at a solid black line - which is taken to be the Braintree- Colchester border (no map key). The extent to which the proposed garden community would extend eastwards into Colchester Borough Council is not shown. So it is not possible to gain an understanding of the full extent of the proposed Colchester / Braintree borders garden community from this map, nor from this BDC Publication Draft Local Plan document.

(page 69) Map 10.4 C - Colchester (not included here): a complex map of Colchester Borough with no map key. One may deduce that the wide green striped areas represent the Colchester Borough areas of the proposed Colchester-Braintree borders and the proposed Colchester -Tendring borders garden communities. The scale of this map is obviously different from Maps 10.2.A and 10.3.B although no scale is given.

(page 70) Map 10.5 D - see attached: the description overlaid on the map itself says... Tendring District Local Plan Publication Draft (2017) Tendring Colchester Boarders Garden Community. The map shows a darker green shaded area with a paler green fringe. The green shading stops at a red dashed line - which is taken to be the Colchester-Tendring border (no map key). So this is again a "half-map" apparently showing the part in Tendring District. The scale of this map is obviously different from Maps 10.2.A and 10.3.B although no scale is given. Again, the full extent of the Colchester-Tendring garden community is not clear

(2) Colchester Borough Publication Draft Local Plan 2017-2033: Section 1
Chapter 10 Maps, page 57 - includes only ONE map 10.1 Key Diagram
This is (looks to be) the same map as on page 66 of the BDC document... Map 10.1 Garden Communities: an overview map with the 3 proposed garden communities shown as orange circles / lozenges.
NO other maps are included.


(3) Tendring District Publication Draft Local Plan: Section 1
Section 1: common section (blue), NO maps
Section 2: local Tendring District section (green)

Appendix A Glossary of Terms
Appendix B Local Maps - includes map B.7 Tendring Colchester Borders Garden Community (page 257). This appears to be the same green shaded "half-map" as in the Braintree Local Plan, Section 1, page 70.

(4) Uttlesford District Regulation 18 Draft Local Plan - inset maps

The Uttlesford Draft Local Plan Inset Map for the West of Braintree Garden Community - not attached.
This map appears to show the entire proposed garden community - although there is no map key. The purple shaded part in Braintree District is more extensive than Map 10.2.A in the Braintree Publication Draft Local Plan (attached).
Which map correctly reflects the proposed extent of the West of Braintree Garden Community?

Wivenhoe Town Council support and agree with the statement by Wivenhoe Society below.
'These comments concentrate on the Garden Settlement proposals within the policy. It is stated "Three new garden communities will be developed and delivered as part of the sustainable strategy for growth at the locations shown on Map 3.3 below and the Proposals Map". There does not appear to be a Map 3.3 or a Proposals Map in the Part I documents. There is a Key diagram showing 3 red blobs indicating the general locations. The Colchester Proposals map shows more, not much more, detail for the East Colchester/West Tendring garden community with the proposed area lying to the north of the A133. The Tendring proposals map for the garden community shows a different area, straddling the A133.
Without any defined proposed boundaries for the communities there is insufficient information to comment on their sustainability and impact. Much more detail on the garden communities should be provided before Part I of the Plan can be judged to be sound. This should include the precise sites being proposed and a justification for choosing these particular locations. More detail on infrastructure is needed, particularly new roads and road improvements and on the impact on existing communities. It is the impact on existing communities that most concerns us as there is no provision to protect the existing character of the area.
More detail on viability is required and justification in terms of future housing needs post 2032.. '

These comments concentrate on the Garden Settlement proposals within the policy. It is stated "Three new garden communities will be developed and delivered as part of the sustainable strategy for growth at the locations shown on Map 3.3 below and the Proposals Map". There does not appear to be a Map 3.3 or a Proposals Map in the Part I documents. There is a Key diagram showing 3 red blobs indicating the general locations. The Colchester Proposals map shows more, not much more, detail for the East Colchester/West Tendring garden community with the proposed area lying to the north of the A133. The Tendring proposals map for the garden community shows a different area, straddling the A133.
Without any defined proposed boundaries for the communities there is insufficient information to comment on their sustainability and impact. Much more detail on the garden communities should be provided before Part I of the Plan can be judged to be sound. This should include the precise sites being proposed, the number of hectares and a justification for choosing these particular locations. More detail on infra structure is needed, particularly new roads and road improvements and on the impact on existing communities.
More detail on viability is required and justification in terms of future housing needs post 2033.

1. The GC at Marks Tey is in the wrong place for a new town.
2. The various committees terms of reference are unclear and what they can and cannot do - this will result in developers getting what they want.
3. Jobs will be difficult to provide - the councils own consultants cite these difficulties.

We welcome the opportunity to comment upon your local plan. We note that the three authorities of Braintree, Tendring and Colchester have coordinated their local plans and that the first part of the plan applies to all three authorities. This approach is to be commended as it gives a much better overview of the effect of development over a wider area than an individual district.

We have been talking to the districts for a long time about their aspirations for growth, it is recognised that large parts of the district are rural and access to public transport difficult. Parts of the strategic road network (SRN) running through the districts are already close to capacity and cannot reasonably cope with large amounts of additional development without significant improvement.

This has been recognised in the governments first Roads Investment Strategy (RIS1) published in 2014, which committed Highways England to commence widening of the A12 between junctions19 to 25 to three lanes, and to prepare options for consideration in RIS- 2 (2020-25) for widening between junctions11 to 16 and 25 to 29.

It has also been recognised that the A120 between Braintree and the A12 is nearing capacity, most noticeably at peak times. Essex County Council has been examining the feasibility of upgrading this route to a dual carriageway. With a view to submitting this for inclusion into a future RIS-2

Until housing and employment is committed the above schemes can really only deal with existing challenges allowing for a limited amount of growth as the designs are based on previously envisaged growth rates rather the much more ambitious level proposed in these consultations. This means the need careful planning to ensure proposed development is in the most appropriate place with the necessary facilities and infrastructure available at the right time and a steep change both in the provision and take up of public transport, if this level of development is to be sustainable

We support the policies in the plan aimed at reducing the need to travel by private car, such as improved walking, cycling and public transport infrastructure, and the provision of high speed broadband allowing people to more easily communicate and work remotely reducing the demand for travel.

See full representation here: http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSE-2017-Part-1-Consultation-response.pdf

The decision to include three new garden settlements in the Local Plan is unsound, and our response recommends that two of the three (SP9 & SP10) should be dropped. We represent 1030 local residents (as of 6 August) who oppose the strategy of a 24,000 home garden community at Colchester/Braintree border ("West Tey")

Our response contains in-depth analysis of why the Plan is not sound, with papers on each of the following:
1. Detailed amendments required;
2. Comments on the Sustainability Appraisal, which we find not fit for purpose;
3. New towns: Learning from the past;
4. A positive vision for north Essex;
5. OAN - the need to remove unjustified uplifts
6. Providing for employment at West Tey
7. Rail constraints
8. Connectivity & Infrastructure
9. Viability - the business case for West Tey
10. West Tey - Costs & Risks
11. The deal for land-owners
12. Community engagement

CPRE Colchester group recognise the theoretical advantages in the garden community concept. However, we do not believe the Council has demonstrated that it can implement its proposals to achieve the balanced communities with sufficient local employment; nor that it is sufficiently certain at this stage that the major infrastructure investment needed can be achieved ahead of the development taking place.
The consequences will be loss of countryside and important agricultural land and the establishment, in the case of West Tey. of a commuter dormitory.

The RSPB supports the intention for "conservation and enhancement of the natural environment" beyond the main settlement boundaries within the main policy.

We also note and support that this is explicitly referenced in paragraph 3.1 of the supporting evidence for this policy and can therefore be considered sound.

We support the proposals for growth in Colchester that initially continue to focus on the urban area of Colchester. However, in recognition that the urban area has a limited and diminishing supply of available brownfield sites, we support the proposal to meet large-scale, housing-led, mixed-use development on greenfield sites including within new Garden Communities. We acknowledge the increasing requirement for greenfield land to achieve the range of sustainability objectives outlined in the emerging local plan for Colchester.

Policy SP2 sets out a Spatial Strategy for North Essex and identifies that:

"Existing settlements will be the principal focus for additional growth across North Essex within the Local Plan period. Development will be accommodated within or adjoining settlements according to their scale, sustainability and existing role both within each individual district and, where relevant, across the wider strategic area..."

"Each local authority will identify a hierarchy of settlements where new development will be accommodated according to the role of the settlement, sustainability, its physical capacity and local needs..."

We support the proposals for growth in Colchester that initially continue to focus on the urban area of Colchester. In recognition that the urban area has a limited and diminishing supply of available brownfield sites, we support the proposal to meet large-scale, housing-led, mixed-use development within new Garden Communities on greenfield sites. We acknowledge the increasing requirement for greenfield land to achieve the range of sustainability objectives outlined in the emerging Local Plan for Colchester.

In its 5th paragraph the policy announces that "Three new Garden Communities will be developed and delivered as part of the sustainable strategy for growth at locations shown on Map 3.3 below and the Proposals Map". The key diagram shown in paragraph 10.1 identifies the three Garden Communities' proposed broad locations. In the accepted format of key diagrams these locations are shown as blobs rather than having specific boundaries which will come forward under future development plan documents at a later date. However, whilst the location west of Braintree is shown in the customary way as a circle the other broad locations are given more specific shapes. In the case of west Colchester / Braintree an elongated shape straddles the A12 indicating an intention to locate development there. In east Colchester / west Tendring the non-circular shape excludes land to the south of the A133 which until now had been considered foe some development, this can be construed as an early master planning decision not to develop south of the A133. The impression of site specific boundaries at this stage could prejudice objective plan making at a later stage and should be removed.

In the 5th paragraph reference is made to "Garden City principles". There have been numerous definitions of these principles since they first came into being. It is therefore important for this policy to be entirely clear as to which version they depend upon. Elsewhere within the plan reference is made to a 'Garden Communities Charter' which was produced as part of the evidence base in June 2016. It describes itself as:

"This Charter sets out 10 placemaking principles developed to articulate the Councils' ambition for the Garden Communities, and help drive forward their development. These are based on the TCPA Garden City Principles, but adapted for the specific North Essex Context in the 21st Century.

The TCPA Garden City Principles provide a good starting point because they were developed to shape the sustainable development of new communities, using the opportunity and economies of scale to innovate and create high-quality places that put people at the heart of developing new communities".

It will necessary for policy SP2 to be clear if it is in fact the TCPA's Garden City principles or the undefined Garden Communities Charter are to be followed as the two are clearly different. Later references in the plan to the Garden Communities Charter indicate the intention to follow that document, in which case a change needs to be made to this policy to accord other references within the plan.

We recognise the enormous challenge faced by local authorities in responding to the Government's housing requirements and in identifying sufficient land for development. However, we are very concerned that in seeking to provide sufficient land to satisfy the predicted demand for homes the Plan will impact detrimentally on the character of the local landscape and existing settlements will be adversely affected to an unacceptable level.

Some loss will be inevitable as further housing is built in the Colchester area and the supply of "brownfield" sites is used up. However, the location and ultimate scale of West Tey GC exacerbates the detrimental impact to an unacceptable degree. In addition, the spatial distribution of the housing growth is not closely aligned to the strategically significant employment growth areas of the Plan and this will result in further strain on the overloaded transport infrastructure.

Copford with Easthorpe Parish Council accept the need for an increased number of homes but would wish to proffer their comments as included in the enclosed document and would suggest that there are other locations fit for development within Copford apart from Hall Lane and Queensbury Avenue

Spatial strategy paragraph 3.1 & 3.2

These paragraphs set out proposals for new strategic scale settlements to be included in the Plan's Part 1. However, it is not made clear which provisions within Part 1 refer also to Part 2. There are considerable overlaps on matters such as sustainability, expected standards of design, climate change, provision of sport facilities and housing standards. Also, it is not clear why, if supposing Part 1 policies only apply to the strategic sites, standards should be different between strategic and local development.

Lack of infrastructure for the area - I am concerned at the lack of infrastructure and the roads are currently congested, the overriding concern for me is that further congestion will lead to higher levels of noise and air pollution. It is my belief that further air pollution will go against the Local Plan policy on healthy living. Another concern of mine is that we do not have enough school and community facility for the area at present and resources will be further stretched should these plans go ahead.

I feel the plan would also add to further contamination to the local wildlife and historical monuments the plans do not even show where the houses will be going or if this site could take 1000 houses. The site itself would appear to be contaminated itself as it has had of contamination from ammunition and also foot and mouth carcass

1.0 Background:
1.1 I am a Chartered Town Planner with over 35 years' experience in both the public and private sector, much of which was spent in the planning, implementation and delivery of large new neighbourhoods/ communities of up to 5000 new homes and in major mixed-use regeneration schemes across the south east. These representations are submitted in a personal capacity as an interested local resident. I am familiar with the representations submitted on behalf of CAUSE (Campaign against Urban Sprawl in Essex), and in particular, the evidence base they have put together on Viability/Deliverability, Objectively Assessed Need (OAN) and Transport, especially the assessment of limitations in future capacity on the Great Eastern Main Line (GEML). I support the conclusions these studies reach and believe these lend further substantive weight to the view that the Plan as currently drafted is unsound.
2.0 Local Plan Section One - Spatial Strategy:
2.1 The Local Plan Spatial Strategy is predicated on a laudable political ambition to plan for the longer term and to plan at a scale that supports more sustainable development. However, the evidence to support the ambition is simply not in place at this time. To include specific policies committing to the scale of development (ie. up to 42,000 new homes) at the three broad locations is clearly premature and unsound in the absence of any certainty that these can be delivered and supported by the necessary investment in infrastructure that would make them viable and sustainable.
2.2 The Infrastructure Delivery Report (May 2017) only covers the Plan period to 2033 and the single biggest ticket item - transport, is conspicuous by its absence. Indeed, paragraph 134 states that 'significant items remain uncosted' and a 'package of measures .....[is] yet to be finalised'. Most critically there is inadequate reference to the A120 or the GEML as major items to be dealt with that would justify the Spatial Strategy and the inclusion of policies advocating the NGCs, and up to 24,000 new homes at CBBGC in particular. Furthermore, as identified in the CAUSE evidence at Appendix 5 the North Essex Viability Assessment (April 2017) makes assumptions regarding the timing of vital infrastructure improvements, particularly GEML and the MRT, that would be towards the end of the projected timeline for the build out of CBBGC, contradicting the Council's stated claim of 'infrastructure first'.
2.3 The Sustainability Appraisal dated May 2017 (SA2017) fails to set out a justification for, or explanation of, the impact of the Spatial Strategy's plan for the longer term growth of Colchester, Braintree and Tendring in three large new settlements; nor why Policy SP9 needs to refer to a maximum of 24,000 new homes. Nor does it adequately address the sub-regional impact and consequences of long term growth at this scale in this location. The SA2017 fails to justify why the Council needs to plan for a total number that exceeds current requirements to 2033 (potentially 42,000 - 7500 = 34,500), and even if it did so, what that number should be. This needs to be more than a simple 'capacity' test of what the three locations could potentially accommodate.
2.4 Housing Needs beyond the Plan Period
None of the documents assessing housing needs and demographic trends address the potential needs and demand post 2037 (Strategic Housing Market Assessment Update 2015, the Objectively Assessed Need Report (2015) and Demographic Forecasts 2013-2037, (May 2015)). Indeed, all appear to predate the emergence of the Preferred Options Consultation in July 2016.
Finally, on OAN I note and concur with the conclusions of CAUSE at Appendix 5 to their representations, regarding the justification for the numbers included within the Plan for Colchester, and the extent to which they are based on over optimistic forecasts of employment growth, for which there is no obvious justification or evidence. Indeed, the evidence is that much of the employment land released in recent years, particularly to the south of Colchester, has ended up as retail or leisure. The rate of take up at the Colchester Business Park (the only employment area of this type in the Borough), has taken many years to come forward, suggesting the demand for commercial space in the town is slow.
2.5 Even if the OAN numbers can be justified, the Plan has also failed to respond to emerging opportunities for other sites that may come forward within the Plan period, eg. Defence Estates land at Middlewick Ranges, that could reduce the numbers required from the NGCs before 2033.

3.0 Viability & Deliverability:
3.1 The delivery of the Council's Spatial Strategy is based upon on an untested use of a joint Local Delivery Vehicle and assumptions about the ability to secure control of land at low cost, combined with an unrealistic assessment of viability.
4.2 The Spatial Strategy for the three NGCs relies on the Hyas North Essex Viability Assessment to demonstrate the viability for deliverability. However, as demonstrated in the CAUSE evidence at Appendix 9 , the overreliance on a simplistic residual valuation model to give a notional minimum land value per gross acre of £100k is inappropriate and flawed for a project of this scale. Given the requirement to purchase land upfront and pay for infrastructure considerably in advance of generating any significant value through land sales or housing completions it is one that will need to be funded largely from the public purse. In my experience the use of a Residual Land Valuation can be appropriate on smaller serviced land parcels but is wholly inappropriate for projects of the scale of the NGCs, and CBBGC in particular. Little weight should be given to the Hyas' Report in assessing the potential viability of such large publicly funded projects, which will ultimately require testing through standard HM Treasury appraisal rules, or similar. The Hyas Report clearly fails to demonstrate that the Councils' preferred mechanism for delivery of their Spatial Strategy is viable and therefore it must be unsound given the significant risk it cannot be delivered. This must also apply to the 2500 new homes required from each of the three NGCs in the plan period. In particular, the Council's evidence (Volume 3 Garden Communities Concept, June 2016 - 'the Aecom Report') suggests there is capacity for no more than 500-900 homes at CBBGC without significant improvements to transport infrastructure capacity.
3.3 The Infrastructure Report admits that there is no certainty over the costings for transport infrastructure and the CAUSE representations highlight a significant under estimation of contingency costs for such an early stage of a project of this scale. Furthermore, the Hyas Report takes no account of the funding of land purchase in the modelling.
3.4 Given the Council's claim (although not one substantiated in policy) of 'infrastructure first', there is a clear risk to the soundness of the Plan to deliver even the 2500 at CBBGC with the viability unproven and no certainty over the transport proposals, in terms of cost and timing.
3.5 Policy SP7 (v) of the Local Plan Section One states that the NGCs will provide 30% affordable housing, and yet the conclusions from the Hyas Report for CBBGC at paragraph 6.3 are already highlighting that under their modelling only with Affordable Housing at 20-25% will 'all scenarios outperform agricultural values'. However, at 30% the Report states 'high cost contingencies could start to impact on viability' and it relies on the optimistic and unproven Garden Communities Premium to meet the required residual land values. Given the evidence put forward by CAUSE (Appendix 10 on costs and risks) that the Councils are seriously under playing the level of contingencies for a project of this scale at this stage, the Hyas Report simply highlights the risk that even at this early stage one of the key justifications for the Spatial Strategy, ie. that the NGC will help to provide a greater access to Affordable Housing, is already under threat.
4.0 Conclusions:
4.1 The Spatial Strategy is as yet unproven in terms of viability and thus deliverability, such that the Spatial Strategy as set out in the policies contained in Local Plan Section One as currently drafted must be found unsound.
4.2 The absence of certainty about the mechanisms for delivery, control of land, justification of scale and provision of new infrastructure investment to meet even existing deficiencies, creates a level of risk that means the Local Plan fails to meet the tests of soundness regarding it being both 'Justified' and 'Effective'.
4.3 Furthermore, the sheer scale of CBBGC, which would result in a new town significantly larger than Braintree, would have a sub-regional impact on a whole range of social and physical infrastructure across all of North Essex and South Suffolk, for which there has been no proper assessment or mitigation proposed through the Sustainability Appraisal or Local Plan. This includes the future viability of town centres, patterns of movement and employment. A much fuller understanding of the appropriate scale of any future growth at CBBGC, as well as the combined impact of all three NGCs should be undertaken before any decision in principle can be made.
4.4 The SA fails to justify development on scale of proposed at the NGCs and at CBBGC in particular is required, nor why decisions are required now in the absence of certainty on deliverability and viability, or analysis of future housing needs beyond 2037.

General comments;

Since their original conception through the local plan process (2015), the Garden Community sites have not developed beyond 'broad locations' on a map. MTPC consider that the stage has now been reached where there should be clearer and more specific detail about where each community is to be located, what they are to provide and how they are to be delivered. The plan is still vague in this respect, though it is noted that there is to be a separate Joint Strategic Growth DPD, which will deal with the Garden Communities in more detail. Whilst MTPC consider that such an approach is appropriate, there should be clearer principles established within the LP to guide the development of these DPD documents. This is because of the effect on surrounding communities and the current lack of detail within the LP as to how they, particularly Marks Tey, are to be treated.

MT has been given no promise of green zone protection from the garden community but adjacent, less affected, communities have! This is the huge issue for Marks Tey and Little Tey, as the broad location clearly engulfs the village and hamlet with no detail and no buffer zone. It seems from meetings with planners that the thought is that Marks Tey will be a suburb, albeit with it's "own identity". This is because of the location of the station, which is vital for the Garden Community, and sits on the outer edge of the broad location. This is not made clear in any consultation document, which makes it impossible for any consultation to happen on what may be a major change, indeed the potential loss of the village. The lack of clarity and the difficulty in understanding the proposals for residents is a major issue of concern. Either the DPD should be done at the same time as the LP or the LP should give affected communities some clear protection/assurance/detail on how the DPD will affect them, else the DPD has a blank cheque.

Therefore, MTPC consider that it is essential that a number of development principles, which clearly define not only how the new Garden Community is to be developed, but also how it is to relate to and potentially integrate with, existing communities is clearly set out in policy. Whilst this may in the main relate to detailed matters, which are not appropriate to explain in detail at the strategic level, it is noted that there is little mention within either the supporting text to the plan or its policies, as to how the impact of such proposals on local communities is to be assessed and positively planned for. and delivery risks identified and mitigated against.

The draft plan contains no reference to the Garden City Principles of TCPA though it is noted that the Garden Community Principles (as contained within the Garden Communities Charter) are referred to, but these should be enshrined in policy - this would be beneficial to assist in the understanding of the concept and to direct what will be a considerable amount of further policy and guidance. (Specific policy comments on this point are made below).

Transport infrastructure is crucial to the success of these communities - and in respect of the Braintree / Colchester Borders Garden Community, there needs to be clear recognition that it is subject to final outcome of improvements to the A120 and dependent upon it's provision or temporary new capacity highway construction linked to the A12 avoiding existing settlements. (In this regard specific comments on SP9 are made below).

A specific concern arising from the above is that in the event that the Garden Communities fail to deliver, there will be a need for a minimum of 2,500 dwellings to be accommodated within the area (potentially 7500 within the wider North Essex) and it is unclear what the burden will be on individual communities such as those in Marks Tey Parish.

The general approach of MTPC is that they will take a positive and supportive approach to such a strategy provided it results in:
* Consideration of and how improvements to Marks Tey can be achieved through the proposed Braintree / Colchester Borders Garden Community, including village sustainability, whilst protecting village identity
* That any new development has to be based on an improved A120
* That it provides clearer evidence of viability and risk management
* That there is clearer evidence of wider support (including financial) from the Government and other bodies
* That each phase of any development needs to be sustainable in its own right and add and improve what exists to guard against the development proposals stalling before full completion.


SP2 - Spatial Strategy for North Essex. This is the policy that introduces the Garden Communities as part of the spatial strategy. The policy refers to Map 3.3 and the proposals map, neither of which appear to have been provided as part of the documentation. The reference to 'substantial additional housing and employment development' to be delivered beyond the plan period is vague and provides little basis on which to comment. The policy refers to Garden City Principles - whilst these are referenced in the supporting text through the North Essex Garden Communities Charter, the need to explained, or guaranteed in policy. There is little in the supporting text to explain this element of the spatial strategy or the role that it is intended to have. These principles should be set out clearly here, or in the specific section on Garden Communities, so that they can be referenced throughout the plan and its policies.

This is an additional representation to that to submitted to Braintree District PDLC in relation to a separate matter.

Policy SP2 refers to the adoption of Garden City Principles but fails to direct the reader to where those principles are defined. How is a decision taker or Inspector meant to interpret the Policy?
As stated in respect of our submission on the Vision (para1.30), the North Essex Authorities vision of what the Garden Communities should deliver is unclear and the concept is untested at this time. Policy SP7 attempts to put flesh on the bone but when peeled back to its bare skeleton, there is no clear justification why any one or all of the planning principles included in Policies SP 7, 8, 9 and 10 cannot be delivered by way of traditional sequential housing growth based upon improving existing transport and community infrastructure.
The only clear benefit in terms of viability might be the ability for the delivery vehicle to buy land on the cheap from landowners who are not otherwise expecting their land to be developed in their lifetime. The North Essex Garden Communities concept is, as a result, no more than a trojan horse project designed to give credibility to what is a flawed planning argument. Far form being an essential element to the Spatial Strategy it is in truth directly contrary to the achievement of the three principle roles of the planning system that also define sustainable development as set out in Para 7 of the NPPF

We generally support the approach set out in this policy but would recommend that the first sentence of the second paragraph includes reference to the "improvement" of existing settlements through future growths. The Plan would thus be more positively prepared.

In addition, the Plan appears to limit itself unnecessarily to explaining how sustainable development principles can be best applied to achieving the spatial strategy by giving only one such example i.e. through ensuring that development locations are "accessible by a choice of means of travel". Ensuring sustainable growth and development has a number of other important principles that can usefully be expressed within such an important policy, for example improving the conditions in which people live, work, travel and take leisure.

Whilst not part of the policy text, we are very concerned that at paragraph 1.38 there is a reference to "The countryside will be protected...". The NPPF/NPPG specifies the extent to which the natural environment should be conserved and highlights the importance of protecting and enhancing valued landscapes, best agricultural land, AONB's and wildlife, it however does not state that the countryside should be protected for its own sake. We consider that designations providing protection across rural areas need to be focused on achieving a particular task. This approach is, in fact properly put at paragraph 1.23 of the Plan where it refers to protection of "natural and historic landscapes, areas of importance for nature conservation and heritage assets". This is an important point because the approach to protection in the countryside is picked up by part 2 policies later and it is important that the part 1 approach is consistent with National Policy and properly justified.

Policy SP2: Spatial Strategy for North Essex
The policy refers to Map 3.3 - but this is not apparent in the published documents.

Paragraph 2 of the policy refers to maintaining distinctive character and role of settlements. However, the policy does not refer to the importance of the historic built environment in North Essex. It is requested that the second paragraph is amended to ensure that reference is made to settlements maintaining their distinctive and historic character. It is also noted that the Policy no longer seeks to avoid coalescence between settlements. This is a significant change from the June 2016 draft Local Plan and has potentially serious implications for the conservation and setting of heritage assets, especially the character of conservation areas.

Historic England requests that the first sentence of paragraph 2 of the Policy is amended as follows:
"Future growth will be planned to ensure settlements maintain their distinctive character and role, and to avoid coalescence between them."

Our comments on the June 2016 draft Local Plan suggested that the supporting text should set out what the policy means for North Essex in respect of high quality of built and urban design. While the wording of the policy has been amended slightly, we remain of the view that the supporting text (paras 3.1 to 3.5) should be set out what this means for North Essex.

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: 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.

see attached statement

We support the overall Spatial Strategy for North Essex, as set out in Section 3 of Part 1 of the Publication
Draft June 2017. In particular, we agree with paragraph 3.4 where it states that around 1200 new homes
will be allocated to Tiptree, West Mersea and Wivenhoe.
We have reservations on both the description and location of the three proposed new communities. We
strongly support the principle, but believe their description as garden communities could be misleading.
The word "garden" implies the low densities associated with the original Garden Cities and traditional
semi-detached suburbs. There are other options that could provide more compact settlements, with a
lower land take, better use of changing building technologies, and greater proximity for all residents to the
surrounding countryside.
We believe the proposed West Colchester new settlement, although the most complex to deliver, is well
located in relation to both the rail and road networks. The other two proposed settlements however have
no direct access to the rail network, which we think is a significant disadvantage. They also appear to be
located on high quality agricultural land. In particular, the proposed Colchester East settlement is sited on
an area of mainly Grade 1 and 2 land. The other two are sited on a mixture of Grades 2 and 3. This
underlines our argument in favour of higher density urban development models that minimise land take.