Policy SP8: Tendring/Colchester Borders Garden Community

Guarantees of infrastructure to be provided before housing is built

The University of Essex notes, and welcomes, the policy and supports the need to integrate the new Garden Community with its own activities and development proposals for the Campus and the Knowledge Gateway.

The University is, however, disappointed that there is no explicit acknowledgement of the need to provide a good quality, preferably dual carriageway, link, from the A120 to the A133, as an early part of the development. The University considers that this link is crucial if existing transport issues, on the east side of Colchester, are to be addressed and if the new Garden Community is to successfully integrate into the local area and not put additional pressure on highway and transport infrastructure.

SP8: Tendring/Colchester Borders Garden Community, point E item 13. should be amended to read 'Primary healthcare facilities as appropriate'.

3.12 Policy SP9: Colchester/Braintree Borders Garden Community, point E item 14 should be amended to read 'Primary healthcare facilities as appropriate'.

3.13 Policy SP10: West of Braintree Garden Community, point E item 13 should read 'Primary healthcare facilities as appropriate'.

- Any new development to the East of Colchester in the Tendring/Colchester Borders should be over the brow of the hill and out-of-sight of existing residents of Greenstead and Longridge Park.Ideally, there should be a 1.5km green, undeveloped buffer between current housing and any new development, this idea is supported by the Greenstead Ward councillors.

- The area between current and new housing should ideally be dedicated as a 'Country Park', for the enjoyment of the occupants of the up to 9,000 new houses and the existing residents of Greenstead and Longridge Park.

- The Strategic Growth Development Plan Document for the area should be the subject of public consultation regarding the position of new development and green space.

- Housing design in the new development should be comparable with the best in Colchester, photos of which have been sent to planners. Please contact Colchester East Action Group for more details.

- The new development should include references to historical Colchester, in the design of buildings and street names.

Any new road in the area should incorporate noise shielding to prevent disturbance to residents from traffic noise

Infrastructure timescale

The A120 Junction should be opened before the first occupancy of any housing.

Considering the abnormally long construction period of the Garden City it is inadequate that timescale for the delivery of infrastructure is detailed at this stage.
Jacobs reports does speak of the 'rapid transit' materialising in two stages as population increases but no where is it mentioned when other critical elements are to be built.

Promoting Sustainable Transport

Submission to policy SP7 (re 5.vii changing behavior) applies to SP8 also.


'Rapid Transit', with particular reference to East 'rapid transit' proposals.

CBC and ECC have now spent 8 years producing reports on the so-called 'rapid transit' proposals for the East development, the latest of them by Jacobs in September 2016 and May 2017 (from which the details here are taken). It is apparently intended to spend yet more money on consultants in further attempts to magic up something that is both affordable and attractive, but the fact is that the two Jacobs reports already demonstrate clearly enough that nothing that could remotely justify the term 'rapid transit' is actually on the cards.

It is now evident (1.78) that CBC want consideration of these 'rapid transit' schemes postponed until the SGDPD inquiries when 'more details' will be available of the garden communities exact sites and layouts. However, so far as the East development at least is concerned, this is an issue that needs going into now, because the reality can be demonstrated already that NO attractive rapid transit scheme is intended or practicable; that (in consequence) the unprecedentedly low postulated % of car journeys by the new residents is unachievable; and that the whole East project is as a result likely to be unsound as far as transport is concerned.

The Jacobs reports conclude with the analysis that there are only two East 'transit' schemes suitable for further pursuing:

(1) what is somewhat fraudulently referred to as 'Guided Bus Rapid Transit via East Hill'. This is in reality only proposed as 'guided bus' on the section between the University and the new settlement (on which section there will be no traffic delays anyway). The rest of it, from North Station via North Hill, High St, East Hill, Greenstead Rd and Elmstead Rd, will be ordinary buses on the ordinary roads, without any further bus priority identified except for the cut-through Greenstead Rd - Elmstead Rd (which has not, it would seem, actually been agreed by ECC Highways). Far from being a step changingly different rapid transit scheme, it would in fact be entirely indistinguishable from the present University bus service! - a point emphasised by the note that it would have to be run by one of the main ordinary local bus companies. The route includes all three of the town's worst congestion spots - North Station roundabout, East Hill / East St / Eastgates level crossing, and Greenstead roundabout. Because of the narrowness of the roads, there is in fact very little possibility of additional bus priority. The consultants' principal justification for this unlikely-to-be-very-rapid scheme seems to be that they made a visit and took a photograph in the inter-peak period which 'proved' that East Hill is not congested! They do however note the Eastgates problem (likely to be exacerbated by more trains in future).
This scheme is stated to be 'economically viable under all but the most pessimistic assumptions'. Its viability is of course due to low costs / its low grade nature! (but there are no opportunities for upgrading it by 'add-on' expenditure).
Also the 'bus priority' between the University and the town centre is stated to be only seen as necessary 'in the longer term' (so nothing on that front for residents in the 2020s), and there is no evidence that such priority measures are actually achievable within the constraints of the roads in question anyway; only the Greenstead roundabout cut-through is specifically mentioned, and there is no statement of support for that from ECC Highways.

(2) closing the railway line between Colchester Town and Hythe and using the trackbed for a guided busway or tram route**. If made as a tram route, that would of course require the whole of the rest of the system from North Station (?) to the East City to be a tram route also, but Jacobs make it very clear that the great extra costs of trams are 'economically unviable under all but the most optimistic set of assumptions', putting that idea firmly off the agenda. As a guided busway it is considered 'potentially viable but downside assumptions in sensitivity testing can easily push it into a negative NPV'.

** Previous work had assumed the construction of a busway alongside the railway line on its south side, for which planning protection was secured in the last Local Plan, with the railway left open. This is now rejected by the consultants - so will CBC now be abandoning the protection? As the Jacobs reports are included as supporting documents, one assumes that CBC do agree with them?

The final recommendation is that CBC/ECC should 'continue to develop the case' for option 1, and 'explore further how a later upgrade to Option 2 could be achieved'. So, far from the new residents getting a high quality facility from the start, even the authorities are now only talking of it possibly appearing one fine day, long after residents have already settled their habits.

Plus the fact is, of course, that the likelihood of getting permission to close the railway line is minimal! - and in the case of not achieving that, the more expensive (and yet more financially dubious) option of a busway alongside the line, with costly extra bridgeworks, would have to be reverted to.

Yet the CBC Local Plan text continues to refer throughout to high-quality rapid transit being provided. Much as one expects local authorities to stretch the truth, there must surely be a point at which false terminology must be removed from Local Plans. The normal definition of 'rapid transit' is trains on separated track, or Light Rail on separated track. Even CBC themselves are not pretending that any of the options being offered in the East are in that league. (The two routes actually being proposed for West in the last Jacobs report are also ordinary bus).

There is then the question of whether, even if some abnormally attractive public transport system were provided, it would actually be of use for most of the East development residents' daily journeys. [We refer here to practicality: the question of the residents' psychological willingness to abandon their cars is covered above]. The easiest focus is on journeys to work (the only type of journey for which current census information on Colchester people's behavior is available, but actually now less than 20% of total journeys). Here the game is given away immediately (AECOM Vol.2, Economy section) where they point out the good selection of major local work locations that would be readily accessible from the East development. Many of them are only conveniently reached by car! The ease of getting to Severalls Park is pointed out (10 mins by car, but an hour by bus). As already mentioned earlier, it is also noted, in good old 'normality = cars' thinking, that the East development will be readily able to attract businesses to settle on the north side by the A120 because good fast road access is what modern businesses want, not town centre locations! (= the employees will come in by car).
The only main employment areas readily accessible by public transport would be the University, the town centre, and Middleborough. (This then takes us on to the point made later that an abnormally high % of town centre workers have free employer parking, discouraging them from using any 'rapid transit' however wonderful, in the same way that this factor has stunted peak-period use of the Park & Ride).
Also the real number of jobs at the Knowledge Gateway is likely to be far less than spoken of, plus University staff are known for their car-dependency despite being offered bus seasons at a quarter the normal rate.

The consultants' claimed viability levels for the East transit schemes are, they state (Jacobs May 2017 p.24), reliant on the assumption that an East Park & Ride site at the University will be present from the early days of operation and provide a base load to support the service in the period when the new community still has a low population. This notion, like the Local Plan's 'evidence-free' support for more P&R sites elsewhere despite the failure of the Cuckoo Farm service to provide any traffic relief in weekday peak periods [see next section], and its massive annual operating loss, has no justification. The Cuckoo Farm site is already easily accessible to almost all of Tendring (everywhere other than Elmstead/Alresford/Wivenhoe) via the A120, and around 30% of its current users do in fact come from Tendring. There is no reason to believe that any significant new customers would materialise for a second site which (thanks to the fast journey to Cuckoo Farm via the A120) is only 2-3 minutes journey time closer! (And most of the people who might use an East site would either be abstracted from the already-very-underused Cuckoo Farm, or from the existing Alresford/Wivenhoe bus/rail services, thereby achieving nothing). If it is intended that residents of the new settlement should drive from home to the P&R site instead of using their nearest transit stop, that is no great achievement and hardly a justification for the £6m cost of a site! The fact is that the East P&R idea remains as it was when struck out of the last Local Plan by the Inspector - a totally un-evidenced fallacy.

Yet another P&R site is proposed off the A120 near the new junction, supposedly 'to intercept trips from the A120' - again wholly ignoring the point that A120 drivers already have access to Cuckoo Farm only 3-4 mins further off. (If Cuckoo Farm were getting over-busy this might be rational; with Cuckoo Farm heavily underused it is a nonsense).

** Supporting evidence for the above statements re Park & Ride will be found in the Colchester Bus Users Group submission.

Education

Demographic studies, (source - Cambridge Econometrics), show predictions of the likely numbers of 4-16 year olds on the east site to be 1000-1100 by 2031. Section 14. merely states that a Secoundary school and primary schools will be provided. It doesn't say when, or whether this will be on within the site. Acorrinding to Essex County Council there is 'no definitive plan to build a new secondary school on the site north of Clingo Hill'. (This relates to the current ten years forcasts). As yet no private funding has been identified that could provide a 'free' school either. Wivenhoes primary schools are at capacity and has no secoundary school. Elsewhere in the document CBC suggest that secondary school pupils from Wivenhoe either attend the Colne in Brighlingsea or the Acadmy in Greensteed. This is very misleading and clarification should be sort from Essex county Council on actually numbers before claims of this nature are made. To Wivenhoe Town Council's knoweldge (gained via the feeder schools and the Colne) in recent history only one student has attended the Acadmy from Wivenhoe. Garentees that a Secoundary school and two primary schools will be built on site, (and prior to occupancy of the housing) need to be made in order to preserve the consistant provition of secoundary school places for all surrounding viallages.


Wivenhoe Town Council also support and agree with Wivenhoe society's submission stating that:-
'This proposal is unsound on several grounds.
(1) Agricultural land: The NPPF states "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality". Almost all of the land proposed for the new community is rated as excellent by Natural England. There is only a limited area of "excellent" land in the region and this is concentrated mainly just to the east of Colchester. In the Sustainability Appraisal for Part I objective 2, labelled "impacts", covers acceptable impacts on high quality agricultural land, important landscape features, townscape features, sites of nature conservation interest and heritage assets. The Appraisal gives an amber rating for objective 2 but this is only because the impact on agricultural land is masked by the assessments for the other impacts - landscape features etc. It would seem more usual for the impact on agricultural land to be a separately assessed.
(2) Impact on European Designated Sites: The land proposed is used as a feeding ground for river birds from the Special Protection Area on the Colne. While a monitoring program on bird population is proposed if it is difficult to see what mitigation could then come forward if bird numbers are found to have fallen.
The Colne estuary and the other estuaries in Tendring include important Natural 2000 sites. While it is proposed that a Recreational Avoidance and Mitigation Strategy will come forward the impact on Natura 2000 of a large population increase to the eastern borders of Colchester could be high. If the intention of the proposed development is to meet local housing need then this might be thought a price worth paying. However if the aim is to meeting regional or national housing requirements then from the environmental point of view it could be argued that development should take place further to the west or, if the demand is national rather than regional, elsewhere in the country.
(3) Location relative to Colchester and to Tendring settlements: The proposed settlement lies mainly in Tendring District but will effectively be an extension of Colchester. One of the advantages of a planned garden development is that it may yield a higher proportion of affordable housing. This affordable housing, however, will not be well related to existing settlements in Tendring. Those on Tendring District's housing list may well have links - employment, family, schools - to the areas where they are currently living.
It is poorly linked to any employment opportunities in the Tendring District and will not help to promote the economy to the east.
(4) Transportation: A major concern is the adequacy of the road network. The A133 is already subject to severe congestion at peak times. It is the only route for cars into Colchester from Wivenhoe given that Boundary Road is a through route only for buses. Greenstead roundabout is a pinch point. It only takes one accident for severe problems to arise. The unpredictability of journey times means that for crucial appointments a safety margin for possible delays has to be allowed when planning trips. The congestion on the A133 and frequent hold-ups is a problem not only for Wivenhoe residents but all those who have to use Clingoe Hill and the Greenstead roundabout. Building 2,500 homes feeding on to this route will cause severe problems and it is difficult to see how a potential settlement of up to 9,000 dwellings is feasible. A route connecting the A133 to the A120 could provide some alleviation but might in practice generate additional traffic on Clingoe Hill. This is not specifically included in the proposals in SP8 nor is access off the A120 is mentioned. An A120 link is shown on the Tendring map but not on the East Colchester map
Section D of SP8 speaks of measures to mitigate the transport impacts and of longer term transport interventions. Without any concrete proposals this would seem to be an empty promise. We urge the Borough to explain what mitigation measures could be put in place given the physical constraints.'

Reference is made to an upgrade to Colchester waste water treatment plant and off-site improvements to the foul sewerage network which is welcomed.

It would be helpful to refer to the phasing of improvements to align the scale and timing of the proposed garden community given that development is expected to come forward after 2033.

Any new development to the East of Colchester in the Tendring/Colchester Borders should be over the brow of the hill and out-of-sight of existing residents of Greenstead and Longridge Park. Ideally, there should be a 2km green, undeveloped buffer between current housing and any new development. This idea is supported by the Greenstead Ward councillors.

- The green, undeveloped area between current and new housing should ideally be dedicated as a 'Country Park', for the enjoyment of the occupants of the up to 9,000 new houses and the existing residents of Greenstead and Longridge Park.

- Any new road in the area should incorporate noise shielding to prevent disturbance to residents from traffic noise.

- The Strategic Growth Development Plan Document for the area should be the subject of public consultation regarding the position of new development and green space.

Also include these if you agree:-

- Housing design in the new development should be comparable with the best in Colchester, photos of which have been sent to planners. Please contact Colchester East Action Group for more details.

- The new development should include references to historical Colchester, in the design of buildings and street names.

This proposal is unsound on several grounds.
(1) Agricultural land: The NPPF states "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality". Almost all of the land proposed for the new community is rated as excellent by Natural England. There is only a limited area of "excellent" land in the region and this is concentrated mainly just to the east of Colchester (see attachments showing Defra land ratings). In the Sustainability Appraisal for Part I objective 2, labelled "impacts", covers acceptable impacts on high quality agricultural land, important landscape features, townscape features, sites of nature conservation interest and heritage assets. The Appraisal gives an amber rating for objective 2 but this is only because the impact on agricultural land is masked by the assessments for the other impacts - landscape features etc. It would seem more usual for the impact on agricultural land to be a separately assessed.
(2) Impact on European Designated Sites: The land proposed is used as a feeding ground for river birds from the Special Protection Area on the Colne. While a monitoring programme on bird population is proposed if it is difficult to see what mitigation could then come forward if bird numbers are found to have fallen.
The Colne estuary and the other estuaries in Tendring include important Natura 2000 sites. While it is proposed that a Recreational Avoidance and Mitigation Strategy will come forward the impact on Natura 2000 of a large population increase to the eastern borders of Colchester could be high. If the intention of the proposed development is to meet local housing need then this might be thought a price worth paying. However if the aim is to meeting regional or national housing requirements then from the environmental point of view it could be argued that development should take place further to the west or, if the demand is national rather than regional, elsewhere in the country.
(3) Location relative to Colchester and to Tendring settlements: The proposed settlement lies mainly in Tendring District but will effectively be an extension of Colchester. One of the advantages of a planned garden development is that it may yield a higher proportion of affordable housing. This affordable housing, however, will not be well related to existing settlements in Tendring. Those on Tendring District's housing list may well have links - employment, family, schools - to the areas where they are currently living.
It is poorly linked to any employment opportunities in the Tendring District and will not help to promote the economy to the east.
(4) Transportation: A major concern is the adequacy of the road network. The A133 is already subject to severe congestion at peak times. It is the only route for cars into Colchester from Wivenhoe given that Boundary Road is a through route only for buses. Greenstead roundabout is a pinch point. It only takes one accident for severe problems to arise. The unpredictability of journey times means that for crucial appointments a safety margin for possible delays has to be allowed when planning trips. The congestion on the A133 and frequent hold-ups is a problem not only for Wivenhoe residents but all those who have to use Clingoe Hill and the Greenstead roundabout. Building 2,500 homes feeding on to this route will cause severe problems and it is difficult to see how a potential settlement of up to 9,000 dwellings is feasible. A route connecting the A133 to the A120 could provide some alleviation but might in practice generate additional traffic on Clingoe Hill. This is not specifically included in the proposals in SP8 . The evidence base documents on transport issues suggest that there would be likely to be congestion at peak hours at the junction of such a link road where it connects with the A133 and that this would impact on traffic flows on Colchester Road leading to Wivenhoe. Section D of SP8 speaks of measures to mitigate the transport impacts and of longer term transport interventions. Without any concrete proposals this would seem to be an empty promise. We urge the Borough to explain what mitigation measures could be put in place given the physical constraints.
The section also talks of the development of a public rapid transit system. It is difficult to see that there is any possible route into central Colchester to the west of Colne Causeway that could deliver a reliable service with predictable journey times. There are various background documents exploring the possibilities but in practice amount to a proposal for a bus link using the existing congested road network. One suggestion is to close the rail link from the Hythe to central Colchester. This would impact on those currently using the train service into Colchester centre who would be required to change at the Hythe. The policy speaks of bus priority measures. Even if feasible such measures could potentially have an adverse impact on existing road users. Without detailed proposals for a rapid transit system this seems to represent wishful thinking and some concrete and feasible proposals need to be included.
Even if a rapid transit system could be developed it is not clear that this would be sufficient to deal with traffic issues. Firstly Central Colchester is not necessarily the desired destination, particularly for journeys to work. Secondly it is uncertain how many people would use the system. Wivenhoe has a frequent and relatively fast bus service to central Colchester (as part of the route uses Boundary Road). It also has a railway station with direct trains to London. However the 2011 census figures showed that 61.9% of journeys to work were by car/van and only 7.2% by bus. There is no reason to believe that residents of the proposed settlement would be more likely to use public transport than those in Wivenhoe. The proposed park and ride could possibly encourage driving from points east of Colchester to use a bus for part of their journey but only those destination is central Colchester.
Within the Plan period up to 2032 it is not clear that the population of the new settlement will generate enough demand to make a rapid transit system financially viable, particularly in the early stages.
One of the merits of the garden settlement concept is that it allows forward planning for infrastructure and amenities and for provision to take place at an early stage. There is a real danger that if the first phase of 2,500 dwellings are built it will then be found that it is not possible to mitigate the traffic impact on the A133 and that the suggested post-2033 additional development is not feasible.

The policy makes no provision for the location and size of the Country Park that will be in Salary Brook. It should be at least 150 hectares in size and create 1.5km of undeveloped space between current housing and any new development. Salary Brook is home to endangered species including dormice which are a European protected species. The plan does not provide sufficient specific protection for this species or sufficient protection of the distinctive setting and sense of place to the east of Colchester provided by the Salary Brook valley, as already identified by Colchester Borough Council in the Townscape Character Assessment (Area H15).

The policy does not make sufficient provision to require new infrastructure to be implemented before development commences; as a result it will risk putting an intolerable strain on local resources, including schools, doctors' surgeries, hospitals, and the congestion hotspot at the A133 on Clinghoe Hill.

The policy does not mention the existing flooding problems at Salary Brook, or include specific mitigations to prevent new development from causing further flooding in what is already classified Flood Zone 3 and where the Council's own North Essex Garden Communities Concept Feasability Study Baseline Compendium states on page 49 'Surface water networks are at capacity... surface water cannot be discharged to the existing disposal network'.

development to the East of Colchester in the Tendring/Colchester Borders should be over the brow of the hill and out-of-sight of existing residents of Greenstead and Longridge Park. Ideally, there should be a 1.5km green, undeveloped buffer between current housing and any new development. This idea is supported by the Greenstead Ward councillors.

- The green, undeveloped area between current and new housing should ideally be dedicated as a 'Country Park', for the enjoyment of the occupants of the up to 9,000 new houses and the existing residents of Greenstead and Longridge Park.

- Any new road in the area should incorporate noise shielding to prevent disturbance to residents from traffic noise.

- The Strategic Growth Development Plan Document for the area should be the subject of public consultation regarding the position of new development and green space.
- Density of housing should be carefully considered to ensure that adequate space is given to all residential properties to ensure wellbeing.
- No development should sit below the A133 , the development needs to be a cohesive community and not split by an A road.
- An innovative rapid transport system must be installed to ensure that such additional traffic movements can be accommodated , this must incorporate cycling lanes.
- In accordance with the concept of garden communities this development must be sustainable and therefore must have jobs that residents can access without travelling.
- The development must have a green buffer around it in accordance with garden settlements for the recreation of the settlement and existing residents.
- 9000 new residents will need access to primary and secondary healthcare so a new GP surgery and additional capacity at Colchester General Hospital is needed.
- 9000 residents will need both primary schools and a secondary school to be provided.

Sean Pordham

There needs to be a "green lung" between the existing developments at Greenstead and Longridge before any further mass development is established in the area around Salary Brook.
Creating a country park between the existing developments and Greenstead and Longridge and the top of the hill and beyond the wooded area known as Churn Wood will act as a buffer between current and proposed developments and keep new housing out of site of the current developments.
Land around Salary Brook is open countryside and not brownfield site and is therefore not suitable for development on such a large scale.
Housing density to be reduced to provide maximum open space for recreation.
Development in Tendring should be based around existing urban areas in Tendring District and not built on boundary with Colchester which will need to provide social infrastructure in an already overcrowded town.

Point 20 in this policy only commits to protect and/or enhance biodiversity. This is contrary to Policy SP7 above and is not consistent with national policy (paragraph 156).

CPRE Colchester group recognises that if the necessary infrastructure and delivery mechanism can be secured, then major development in this location would be acceptable, especially given the proximity of the University and its Knowledge Gateway and therefore the likelihood of local employment.

It is essential that in any development the Salary Brook valley and adjacent woodland is safeguarded.

We have concerns over traffic in the pretty country lanes that are already used as cut through routes for drivers. We consider the area around Crockleford Heath to be a real beauty spot and are concerned it will be lost to a housing estate, perhaps it does not need to be crammed altogether and we can leave space for the gardens and space to walk in and enjoy.

East Colchester benefits from and supports the growth of the University, the Knowledge Gateway (one of Colchester's three Strategic Economic Areas), and the town centre. There are, therefore, realistic prospects of local employment for residents of a new community.

Infrastructure improvements ahead of development will also be required, but not on the same scale as the West Tey GC proposal.

Development of an urban extension to the built up area is less harmful in countryside terms, provided that the Salary Brook valley (including adjoining woodland), is safeguarded.

The principle of development in this location is considered justified and effective.

Policy SP7 affirms that detailed master plans and design principles will be set out in a future separate development plan documents. However, policy SP8 sets a specific requirement for the location of the proposed new country park, it states:
"Safeguarding the important green edge to Colchester will be essential with a new country park provided along the Salary Brook corridor and including Churn Wood".

Whilst fully accepting the need for a country park as part of this Garden Community it is inappropriate for a single site-specific designation to be made in advance of the formal master planning process as it will not be considered amongst other options or strategies. We therefore ask that specific reference to country park location be removed from SP8 and offer the following justifications:

1. To accord with the other two proposed garden communities which do not have site specific locations for country parks.

2. The future location of a country park will need to be tested against alternative locations within the site and community recreation strategies. For example, there is an option for a series of smaller country parks connected by generous green corridors which is likely to of a higher biodiversity value and offer a more sustainable proximity for the new residents on the proposed community. The existing Salary Brook park and nature conservation area is a significant green asset for existing residents who have direct access to it. The proposed country park will be an asset to the wider community of Colchester and west Tendring but also needs to address the needs of the future generations of the new Garden Community.

3. The concept of retaining a green gap between Colchester and the new garden community is un-tested and should be fully considered at the master planning stage. For example, a key development principle in the Poundbury development brief was that Poundbury should be seen as an extension to Dorchester and not as a separate settlement as this would become a dormitory suburb.

As a resident of East Colchester, I am entirely in favour of the proposed Tendering/Colchester Borders Garden Community as currently proposed under SP8 of the Colchester Borough council Draft Local Plan and with specific reference to the following paragraphs/provisions:
Paragraph 15 which refers to 'A network of multi-functional green infrastructure will be provided within the garden community incorporating key elements of the existing green assets within the site. It will include community parks, allotments, a new country park, the provision of sports areas with associated facilities; and play facilities'.
It is essential for the proposed garden community and the adjacent other settlements of Colchester, Wivenhoe and Elmstead Market in order for it to operate as a community with a discrete identity and sense of pride in and enjoyment of place, that there should be sufficient green separation of the new community and Colchester East and Elmstead. I therefore support the provision and adoption of an area incorporating Salary Brook and up to and including the ancient woodland on the brow of hill and beyond, right along the edge of Colchester from the A133 to Bromley Road as country park for the continued enjoyment of residents of both areas and as detailed in paragraph 15 in SP8. A width of 1.5 km would be good for this, but as a minimum this should be not less than the area incorporating the brow of the hill opposite Greenstead and Longridge so that the new garden community is invisible from East Colchester, as is East Colchester from the residents of the new garden community.
Paragraph 19 which refers to 'landscape buffers between sites and existing developments in Colchester, Wivenhoe and Elmstead Market' which is alluded to above, essential for the genuine development of a sustainable and discrete community in the new garden village proposed and so as not to invade, transgress or otherwise impinge on other local settlements, for the benefit of residents in all areas.
Paragraph 20 which refers to the proposed 'enhancement/protection of heritage and biodiversity', and which would also be accommodated by the incorporation of the green buffer up to and including the brow of the hill opposite Greenstead and Longridge in East Colchester which contains flora and fauna in the unique landscapes of marshy brookside, meadows, ancient hedgerows and ancient woodland which this area represents, thus preserving this biodiversity for the future and for the enjoyment of residents of all communities.

While I, in principle, support the need for additional housing in the North Essex Area, this support would be dependent on a number of issues.
1. The new garden community should be distinct and separate from the Colchester areas of Greenstead and Longridge Park, preferably by maintaining a distance of at least 1.5km from the Salary brook nature reserve (i.e. Over the brow of the hill and not seen from these Colchester suburbs). This principle is supported by the local Greenstead Ward Councillors.
2. The space between Greenstead / Longridge Park and the new garden community should be designated as a country park primarily for the use of the residents of these areas.
3. Any infrastructure e.g.a junction with the A120 and light transit rail should be in place before residents are able to move into houses built in the new Garden Community.
4. Roads built would require sound shielding to prevent excessive noise.
5. With the governments proposed ban of petrol and diesel cars from 2040, provision needs to be in place to ensure there are enough car parking spaces within the boundaries of the properties built e.g. On road parking should be avoided at all costs. This way suitable charging points for electrical cars would be future proofed.
6. The housing built should be to the highest technical standards and comparable with the highest quality housing stock in the borough of Colchester.

All development should be completely out of sight of Longridge and Greenstead resident ie well over the brow of the hill. A green buffer of at least 1.5 km from salary brook and any new development, as supported by Greenstead ward councillors.

1) The policy makes no provision for the location and size of the Country Park that will be in Salary Brook. It should be at least 150 hectares in size and create 1.5km of undeveloped space between current housing and any new development. Salary Brook is home to endangered species including dormice which are a European protected species. The plan does not provide sufficient specific protection for this species or sufficient protection of the distinctive setting and sense of place and bucolic tranquility to the east of Colchester provided by the Salary Brook valley, as already identified by Colchester Borough Council in the Townscape Character Assessment (Area H15).

2) The policy does not make sufficient provision to require new infrastructure to be implemented before development commences; as a result it will risk putting an intolerable strain on local resources, including schools, doctors' surgeries, hospitals, and the congestion hotspot at the A133 on Clinghoe Hill, not to mention extra (and very much not welcome) air pollution that would inevitably be emitted by the excessive traffic.

3) The policy does not mention the existing flooding problems at Salary Brook, or include specific mitigations to prevent new development from causing further flooding in what is already classified Flood Zone 3 and where the Council's own North Essex Garden Communities Concept Feasability Study Baseline Compendium states on page 49 'Surface water networks are at capacity... surface water cannot be discharged to the existing disposal network'.

And the following under Section 2, Policy DM8:

1) The Colchester Borough Council policy makes no provision for new homes to be purchased by the council or its nominated partners at a proportionate discounted for use as affordable or council housing, despite the parallel Tendring District Council having such a provision within the equivalent part (Policy LP5) of their Local Plan. Given the current housing crisis, this provision should be applied across all of the relevant councils, rather than by Tendring alone.

Colchester's infrastructure cannot cope with the number of houses it currently has. Schools, doctors and the hospital are at breaking point.
Flood risks are a massive issue to the residents of Longridge and the garden community would increase this risk if situated too close.
There are many protected species living within the salary brook trail and a massive development would impact negatively upon the wildlife and the wellbeing of the existing residents.

Infrastructure issues.

Boundaries between developments.

Premature pending evidence the Plan is viable and deliverable

Severe risk of flooding will be increased to the residents of Longridge along the salary brook.
Infrastructure won't cope with a large number of new homes and the roads of Colchester are awful as it is. This impacts on pollution and commuting time into to the town for work.
The schools, doctors and hospital cannot cope with such a large number of new residents and more should be done to ensure unused property is utilised to house people.
There is a lot of wildlife in the proposed area and species such as dormice would be at great risk.

We acknowledge the aspiration of a country park and the green infrastructure network. We also expect the detailed design of the Garden Community to avoid indirect impacts to nearby Sites of Special Scientific Interest (SSSIs)2 and Special Protection Area (SPAs)3. At paragraph 8.4 the loss of off-site habitat (commonly referred to as functionally-linked land) is acknowledged. The requirements for bird survey and assessment, phasing of development and provision of suitable migratory habitats should be translated into policy. These requirements were identified in the AA Section 1 Report and we advised on these in our letter of 28 June 2017 (our ref: 215973). Point F.20 in Policy SP 8 could be a suitable place to include these requirements. Please also see our comments in Other Advice below on the Strategic Growth DPD, and our advice on paragraph 8.5 regarding policy commitment to a RAMS.
We note in policies SP 8, SP 9 and SP 10 that a Strategic Growth DPD will be developed between the three North Essex Authorities. It is not clear to us what the status of this forthcoming DPD is, nor a timescale for completion. Given our concerns on the strength of Policy SP 6 with regards the protection and enhancement of the natural environment, it is unclear whether the DPD would be sound with regards to the NPPF.

Persimmon Homes support the creation of the Tendring / Colchester Garden Community.

Policy SP7 (v) has an absolute target of 30% affordable housing. However, Policies SP8 Part B, SP9 and SP10 states 'including a minimum of 30% affordable housing'. Persimmon Homes object to Policies SP8 Part B, SP9 and SP10 reference to the affordable housing target being a 'minimum'. The Local Plan must set out clearly the target it is seeking to achieve and, in line with Para 173 of the NPPF, assess the implications for development viability having regard to the scale of obligations and policy burdens of the development plan as a whole.

It is considered that an uncapped target does not provide certainty and could place a policy burden that would threaten viability. The market and purchasing decisions factor in policy requirements and not having clarity would give rise to significant uncertainty that would not assist delivery.

Policy SP8 (Tendring/Colchester Borders Garden Community) defers consideration of the final housing numbers, nature, form and boundary of the new Garden Community to a 'Strategic Growth DPD'. The DPD is intended to provide the framework for the subsequent development of more detailed masterplans.

Persimmon Homes made representations to Colchester regarding the inclusion of 39ha of land at St John's Road, Colchester within the Tendring / Colchester Garden Community and have submitted a Site Delivery Statement (September 2016). The technical work undertaken to date demonstrates that land at St John's Road, Colchester is suitable, available and achievable.

The inclusion of land at St John's Road, Colchester would assist in delivering the objectives of Policy SP8. Furthermore, its inclusion would not harm the aims of maintaining separation between the new garden community and the nearby villages of Elmstead Market and Wivenhoe. Furthermore, it would not prejudice the creation of a new country park along the Salary Brook. As detailed in the Site Deliverability Statement, the site has good connections close to the edge of the town and can afford a landscape / open space buffer to the existing built up area.

The Housing Trajectory (p72) details 1,250 homes coming forward between 2017‐2033 from the Tendring / Colchester Borders Garden Community. The Housing Trajectory contained in the 'Housing Land Supply Statement' details both garden communities delivering new homes from 2023/24 (50 pa each) increasing to 100pa (2024/25) and then 150 dpa 2027/28. The Local Plan is predicated on the new Garden Communities delivering early in the plan period.

Extract from Housing Trajectory






As detailed in the Deliverability Statement, land at Buildings Farm is considered deliverable. It is available now, offers a suitable location for development now, and is achievable with a realistic prospect that housing will be delivered on the site within the timeframe envisaged within the Housing Trajectory.

Objection 5 ‐ Section One Maps - 10.1 Key Diagram (p57)

Whilst the exact boundaries of the garden communities are not fixed at this stage, the Key Diagram at p57 details a notation for 'garden communities'.

Part of the evidence base supporting the Local Plan is the report 'North Essex Garden Communities, Concept Feasibility Study, AECOM, June 2016'. Volume 3 includes 'Garden Communities Concept - options and evaluation'. In relation to East Colchester / West of Tendring, three options are presented; Option 1 (Southern land focus), Option 2 (A133 to Colchester‐Ipswich Rail Line and Option 3 (North to South Wrap) albeit decision on the final boundaries is deferred to the DPD.

The Key Diagram (p57) in the draft Local Plan, whilst indicative implies a Southern Land Focus for the garden community. Furthermore, the draft Local Plan Policies Map notation of the 'Garden Community Broad Area of Search' (Green stripes) also implies a Southern Land Focus for the garden community.

It is considered that the consultation Local Plan and associated inset map are misleading as to the broad area of search for the East Colchester / West of Tendring Garden Community as identified in the Local Plan evidence base. Furthermore, it is considered that identifying one location (i.e. Option 1 - southern land focus) is prejudicial to the consideration of wider options that have been identified for the Garden Community.

The presentation of the East Colchester / West of Tendring Garden Community within the draft Local Plan and associated inset gives the impression of the pre‐determination of the options. Furthermore, it is misleading as to the area under consideration. This approach has potentially misdirecting views and prejudiced the consideration through the Regulation 19 consultation of the wider options identified within the evidence base.






The Preferred Options draft Local Plan was presented to the Local Plan Committee on the 5th July 2016. Policy NC3 of the draft Local Plan sought to allocate land at St Johns Road for 700 dwellings. The evidence base clearly supported the fact that the site is a sustainable location and can be supported as a housing allocation. Between the publication of the draft Preferred Options Local Plan and the committee, a further document was published - Schedule of Changes and Revised Plans. This report removed the site at St John's Road from Policy NC3 and the proposals map covering North Colchester. It is understood that the specific site allocation was not taken forward due to deferring the decision around the precise boundary of the new Garden Community within the broader East Colchester area.

Strong concerns are raised that the emerging site allocation was removed pending consideration of the boundary of the garden community a decision on which is now being deferred to the DPD. As detailed in the Delivery Statement attached, St John's Road is a sustainable site that can meet its own infrastructure needs arising and being delivered either independently or as part of a garden community. It is considered that judged upon its merits, the site scores comparatively well. The site is located within the growth location of urban Colchester and has a close relationship with major employment areas within the town. This relationship is acknowledged at para 12.31 of the draft plan;




The Local Plan should either commit to St John's Road forming part of the Garden Community or make a specific housing allocation in its own right.

The development at St Johns Road would accord with the Council's Spatial Strategy as set out in Policy SG1 which identifies Colchester town as the top of the hierarchy. It also ranks sites by way of location, with central areas being the most sustainable, followed by areas to the north / south
/ east and west providing the next sub‐level of well‐connected, sustainable locations for growth. The next tier down is the Garden Communities. It therefore follows that St Johns Road, as an area surrounding the built‐up area in a well‐connected and sustainable location, is an optimal location, second only to development within the Town Centre within the Spatial Strategy.
We welcome the identification of three new settlements across the North Essex HMA. This shows not only a commitment to delivering housing not only for this plan period but beyond 2033. However, we do have a point of consistency to raise about the target for affordable housing in each new settlement. In SP7 the target of 30% is clearly set out in part v. However, in Policy SP8 and Policy SP9 these targets are set out is minimums.

See attached letter