Policy SP4: Providing for Employment and Retail

The need for employment is sound, but the plan does not consider that a significant proportion of the current working population commute to London, If employment is to be addressed it needs to be high quality rather than just retail

The University of Essex supports the Borough Council's commitment to, and the focus upon, providing a strong, sustainable and diverse economy, both within the Borough and across North Essex. The University considers that it is for the Borough to determine the exact level of new land, and jobs, needed to achieve these objectives, but it does note, welcomes, and supports, the acknowledgement (para 5.10) that the Tendring Colchester Borders Garden Community, has significant potential to deliver both residential and employment opportunities. The University looks forward to working with Colchester and Tendring Councils to help realise the potential of this strategic commitment, particularly in terms of the opportunities that it opens up for new technology based businesses associated with the University itself.

It has been extremely difficult to analyse the plan since the garden community forms such a key part in the delivery of the employment and retail space that we require.
Since it is based upon the concept of a garden community the plan at first sight appears flexible enough to promise major benefits but the lack of specific detail, identified funding streams or the control mechanisms required to implement the garden community reduces the effectiveness of the plan to a wish list.
The principle driver and focus for the proposed garden community is the need to provide housing. The detailed housing assessment Braintree, Chelmsford, Colchester, Tendring Objectively Assessed Housing Need Study November 2016 update attempts to identify the unknowns that can be projected through known and historical trends. The anticipated additional growth in the region is postulated through the removal of historical constraints to the supply of housing to be removed.
Page 34 outlines London's huge housing need in the South East but then assume a proportionately smaller increase for our area despite historical precedent and the anticipated increased incentive due to increasing price house price differential.
When considering how best to generate more employment and retail opportunity it is important to begin with a true assessment of the assets and advantages of a location.
Colchester Borough is categorised as having "developed a strong economy, linked to its 'central place' functions and to the town's historic character, cultural activities and the university. Major retail and leisure services are also located both within and adjacent to Colchester town". Colchester's "central place" function has declined significantly over the last 20 years to a position where many sections of the centre struggle to retain viable employment and retail businesses. Over the same period the major developments have taken place and continue to take place at out of town locations with poor public transport necessitating the increased use of private cars.
While the ports of Felixstowe and Harwich are major assets for the U.K. their development has been restricted relative to our European members by their poor infrastructure links and requirement for improvements to be financed by the ports themselves. While Colchester and Essex University are participants in the Essex Haven Gateway initiative trade passing between the Colchester area and the ports is low, the bulk of the commerce flowing to and from other areas of the UK.
The plan does not specify how the desired outcome of the garden community will be achieved. As stated earlier the prime driver for their creation and their finance would not be central government, as in the creation of the post war new towns, but developers.
No new additional powers or plan based prescriptive designs are envisaged in order to create the new garden community. There are many small scale examples repeated across the borough where within new developments space originally planned as retail are redeveloped for residential use when anticipated retail clients are not forthcoming at the prices requested.
It is clear that within such a large development which is expected to provide for future employment in addition to housing requires a re-balancing of power between locally elected representatives and developers. Situations such as the development of housing between Cowdray Avenue and the river Colne despite being against the wishes of the elected representatives of Colchester need to be anticipated and incorporated within the plan.

When considering the development the council must consider who will buy the new houses, local residents may buy some of the new housing but the numbers proposed will be far in excess of local resident needs. Does the council even know what percentage of people how have purchased houses in the past years have been local or who have moved from outside the Colchester area?
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. When my wife left her financial job in London she found getting work in Colchester difficult. She took part on a "Job Den" article/assessment organised by a Colchester newspaper. The first thing that the panel said was for to "Dumb Down" her CV as the Employers in Colchester would think she was over qualified, she worked in the back office administration areas in London, she was NOT a trader or Fund Manager. She is on approx. 1/4 of the wage she was on in London. On the plus side she no longer has to use the terrible train service.

The plan does not give any tangible evidence how employment in the new Garden communities will be realised just allocating space will not realise high quality skilled jobs. It also does not state what will happen if the employment is not realised i.e. will houses still be built?

Colchester/Braintree borders will not be able to meet the Garden Communities charter goal of one job per household or nearby. See detailed response in appendix 6, providing for employment, on page 50: http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSE-2017-Part-1-Consultation-response.pdf

A key objective for the Colchester Plan is to strengthen and diversify local economies to provide more jobs and achieve a better balance between the location of jobs and housing, which will reduce the need to travel and promote sustainable growth. Background evidence work to support the emerging Plan finds that the Colchester/Braintree Borders Garden Community is well placed to take advantage of employment opportunities that would be created by construction of the Garden community plus new technology -based businesses, together with access to employment opportunities in Colchester, meeting the growing need for local services, and accommodating elements of the logistics supply chain. Major strategic allocations on land North of London Road, Stanway, and a large free standing strategic growth opportiunity on land East of Marks Tey would achieve this objective and create benefits in both the short or longer terms from the positive spin-offs associated with the wider Garden Community.

Support is extended for policy SP4, which adopts an annual jobs forecast for Colchester of 928 for the period 2013 - 2037) using the EEFM (East of England Forecasting Model). This forecasts total job growth based on past trends. This results in the requirement of between 22.0 and 55.8 hectares of B use employment land according to baseline and higher growth scenarios.

A key objective for the Colchester Plan is to strengthen and diversify local economies to provide more jobs and achieve a better balance between the location of jobs and housing, which will reduce the need to travel and promote sustainable growth. Background evidence work to support the emerging Plan finds that the Colchester/Braintree Borders Garden Community is well placed to take advantage of employment opportunities that would be created by construction of the Garden Community plus new technology -based businesses, together with access to employment opportunities in Colchester, meeting the growing need for local services, and accommodating elements of the logistics supply chain. A large free standing strategic growth opportunity would also benefit in the same way and would benefit in the longer term from the positive spin-offs associated with the wider Garden Community.

Support is extended for policy SP4, which adopts an annual jobs forecast for Colchester of 928 for the period 2013 - 2037) using the EEFM (East of England Forecasting Model). This forecasts total job growth based on past trends. This results in the requirement of between 22.0 and 55.8 hectares of B use employment land according to baseline and higher growth scenarios.

We do not find the Plan's strategy sound in terms of providing opportunities for employment and economic growth appropriate to the area's circumstances. A stand-alone garden community located at a distance from areas of economic activity will not be sustainable because job creation - especially those of higher value - will not keep up with the increase in population.

Given the backdrop of existing high out-commuting in the Housing Market Area, an over-supply of employment land, severe transport constraints and the current market challenges to developing land outside strategic and central urban areas, we do not believe that the employment land to be allocated at West Tey GC will be developable and viable. It has little to offer as an independent employment hub, and will inevitably have a disproportionate number of long distance commuters, principally to London and Stansted. A focus on the commuter line not only weakens the local economy but creates pressure on a service which is already stressed and forecast (by Network Rail's Anglia Route Study) to be standing room only by 2043. Commuter-focused development simply encourages long distance travel, which is inherently unsustainable in terms of economic cost, lifestyle and emissions.

Employment provision at the new garden communities is key to their success or failure, yet Marks Tey is not recognised as a strategic economic area by Colchester, Braintree or Essex councils and no economic vision for West Tey GC has been provided. The ambition of the north Essex garden communities charter to offer one job per household within West Tey, or within a short distance by public transport, is based on an aspirational scenario, yet the evidence base would seem to indicate that it is unrealistic and unachievable.

The quality of agricultural land is an important consideration to be taken into account in allocating land for development - as well as the longer term issue of local food production to meet a growing demand from an ever increasing population. In this respect, it is considered that the soundness of the Plan is undermined by the fact that the two stand alone garden community proposals (east and west of Braintree) would result in the loss of large areas of high quality and versatile agricultural land - ie Grade 2 of the Agricultural Land Classification (Very Good). The importance of this land is reflected in the contribution of the agricultural sector in the Essex Haven Gateway to the county's total GVA - where, at 2%, it is double that of the county as a whole. In addition, Braintree District has the highest number of of enterprises (405) in this sector - far beyond any other district and, together with neighbouring Uttlesford, represents over a third of all Essex enterprises in the sector.

The Essex Economic Commission report on the Greater Essex Economy (published in January 2017) shows that growth has been slower than average in Greater Essex for the UK's fastest growing sectors. However, a number of sectors are growing faster in Essex relative to the UK as a whole but these are mostly in lower paid service industries - eg social work, recreation, public admin, accommodation and catering. Sectors regularly cited as providing key opportunities to drive future growth in the county, building on existing assets and highlighted in local authorities reports are not generally well represented in the Mark's Tey or Braintree areas - such as, advanced manufacturing, life sciences and healthcare, digital and creative services, finance and business services, logistics and renewables. As a result of this under-representation in the key growth sectors, we are concerned that the potential for creating sufficient higher value jobs for the proposed level of residential growth will be significantly weakened.

The ENLA notes that out-of-town business parks are no longer the preferred option for many businesses, and growth sectors (services and creative), tend to favour town centre locations. The allocation of land for employment at West Tey GC, per se, will be insufficient to create employment for the inhabitants of a settlement of between 13,000 and 28,000 dwellings. Land promoters have focused on the construction phase of the scheme as an employment generator, rather than the long-term and permanent needs of the settlement.

Land should be allocated for employment use in response to demand not a theoretical exercise in an Annual Jobs Forecast, which will only be realised if developers and occupiers consider the location attractive. Even with optimistic forecasting there will inevitably be a significant lag between the growth of housing and the rate of growth of job opportunities that will mean that for a significant period the current balance of out commuting is unlikely to change. The factors that may influence the rate of take up are likely to be infrastructure led rather than availability of labour in this area. The consequence of an over-supply of land based on over optimistic forecasting is that there will pressure to use the land for other purposes, thus undermining one of the central tenets of the Spatial Strategy that this will give the Councils greater control.

MTPC considers that whilst it may not be possible to be specific at this stage, the supporting text and policy should give a clear indication that the Garden Communities will be expected to deliver on site employment opportunities, including specific provision for live / work units, business start up units and other innovative approaches to supporting the economy, in accordance with the stated principles of the Garden Communities and that some start on this should be included in the first LP period to build up demand for residential development and aid financial viability. MTPC has suggested expansion of the Andersons/nurseries site between the railway and the A12 for this purpose.

The Plan shows little understanding of how real jobs are created. It over-centralises employment in large employment zones, rather than letting the economy breath. It fails to link housing to local jobs as required by the NPPF. It locates large scale housing at West Tey where house prices will be driven by commuters and be unaffordable to people on local salaries.

I support CAUSE's response.

The reasoned justification focuses (e.g. at paragraph 1.50 on the Plan providing for "more jobs" and achieving a "better balance between their location i.e. with housing". However, the Plan should make clear that the focus should also be on making the relevant districts attractive to inward investment, in that regard and in other respects securing economic success and performance across diverse sectors. These important facets appear to be missing and in order for the Plan to be properly articulated in terms of the Plan being positively prepared, justified, effective and consistent with National Policy.

In terms of the requirements for Employment Land it is wholly unacceptable that the future of these three districts are being planned on the basis of such wide differentials between the two scenarios, in the case of Colchester a difference of nearly three times. This does not make for effective plan making because of the uncertainty it creates. If the higher growth scenario is adopted there could be considerable amounts of land identified for employment development that will not come forward and could constrain sites that are otherwise suitable for other development that could contribute towards economic of housing growth.

Whilst the policy relates to the provision for Employment and Retail, nowhere in the policy are retail needs considered, assessed or planned for. This is a fundamental flaw in the drafting of the Development Plan which as a result is ineffective, inconsistent with the NPPF (paragraph 20) requiring Local Authorities to plan proactively and positively to help achieve economic growth.

In the case of Colchester, the Employment Land Needs Assessment (2015) by NLP considered four growth scenarios to inform the requirements for employment land over the plan period1. The Study considered that baseline job growth and future laboursupply were the two most robust scenarios and discounted the higher growth scenario (higher past development rates).

Within Section 1 of the Plan, there is no evidence for why a "higher growth scenario" should be considered, what it is based on or its methodology. As we explain further in this letter with our worked example, applying such a higher growth scenario simply overflates an already inflated figure of need.

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.













































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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.

This section should be amended to include reference to sources of employment in London. The Plan rightly refers to the excellent connections between Colchester and London and also acknowledges that residents travel outside of the HMA to work at Stansted Airport. The previous draft of the Plan acknowledged that residents commute out to London but this is not reflected in the Plan. The absence of this raises doubts about the justification of the Plan.

see attached