Policy SP9: Colchester/Braintree Borders Garden Community

The National Planning Policy Framework outlines a duty to ".......contribute to protecting and enhancing our natural, built and historic environment....". I contend that Policy SP9 will give rise to the direct destruction of a huge area of natural farmland, woodland etc. by conversion to a built-up area is in direct conflict with this duty. This destruction will not only apply to the land immediately affected; it will also have a strongly negative effect on a very wide area outside of the new 'Garden Community" by changing the very nature of the district. Consequently, Policy SP9 runs against Policy SP1 The presumption in favour of Sustainable Development in that it does not ".......contribute to protecting and enhancing our natural (built and historic) environment....". SP9 should therefore be dropped in favour of development within and adjacent to the area's major settlements.

RE Eyre-Pugh, Jordans Farm, CO6 2AZ.
About D7:specifically the suggestion to relocate the newly refurbished Marks Tey railway station into the centre of the new garden community.

I submit below some short comments on why I consider the Local Plan SP9 is not sound
a) the trains will not manage with the commuters living in the 23,000 houses
b) the road infrastructure is wholly inadequate and the A120 dualling between Braintree and the A12 needs to be operational before any houses are built
c) the area would destroy important Grade 2 agricultural land

As long as A12 and A120 are improved first

I am a resident of Messing and I am writing to you to protest about the proposed West Tey development which I understand will border on my village. I understand that this will involve the construction of some 23,000 houses, an influx of approximately 56,00 residents who will own about 36,000 cars. My reasons for objecting to this massive development which amounts to another Braintree on our doorstep are:

1 This is rural area and does not have the infrastructure to support a development of this size. Currently there are:-

a) Insufficient doctors in the area with patients waiting 2/3 weeks for an appointment.

b) Not enough dentists are available to meet the needs of the current residents.

c) Schools could not accommodate the needs of a major influx of children.

Our experience of house planning in this area is poor. Houses are built without enough consideration for the impact they have on the limited resources of the area.

2) The roads in this area are poorly maintained and congested with the increased traffic of recent housing developments. The traffic from the proposed West Tey development would be unsustainable.

3) Who is going to buy these 23,000/24,000 houses? is they sufficient industry/employment in the area to support this development. Commuters would have to rely on Marks Tey station which is small, difficult to access and the trains are already full. Those commuting by car would cause
further congestion on an already congested A12.

4) Every time we shop at Stanway we are concerned at the masses of houses being built there. As far as we are aware there has been no provision for any entertainment (cinema), shopping, schooling or medical facilities. We supported the building of a cinema in Stanway but this was rejected in favour of one near the new football stadium (another area of massive over development and miles away from Stanway).

In conclusion, we in common with most people who lived here for many years, do not want to see our part of Essex concreted over with housing developments. This development will result in the loss of 3,200 acres of countryside which will be lost forever. For the foregoing reason I am against the proposed West Tay development which, quite frankly, I think is ill conceived and flawed.

Thank for your attention,

House prices are going to be between 60 and 80k more the London side of Colchester and this makes the West much more profitable and therefore presents a significantly reduced risk to Colchester tax payers.

Feering Parish Council wish to see green buffers designated and shown on the proposals maps as follows:
a) in an eastern arc around and historic centre and conservation area of Feering village which includes the church (Grade I Listed) and green plus various listed buildings
b) around the tranquil rural hamlets of Skye Green, Langley Green and Stocks Green which include the listed buildings Cockerell's Farmhouse & The Old Cottage in Skye Green, Poplar Hall & Old Wills farmhouse on Little Tey Road
c) around Prested Hall, Grade II listed.

The green buffers are to prevent the coalescence of the eastern edge of Feering Parish with the western edge of the proposed garden community. Such coalescence would lead to the detriment of the character and rural setting of the hamlets on the eastern / NE side of Feering village and to the listed building of Prested Hall. The limited location of these green buffers would not contradict national planning policy as it not a wholesale designation of swathes of countryside in the eastern part of Feering Parish but is limited to specific areas.

In addition, FPC request that the landscape around Langley Green is protected. The 2010 Braintree Historic Characterisation Project describes that zone HECZ 12.5 as "sensitive to change". Some field boundary loss is noted, but the report states that "the overall structure of the landscape survives and is of ancient, probably medieval origin" - there are moated sites. Prehistoric ring ditches are also noted.

The proposed local plan is unsound, as the published proposals for a garden community at West Tey fall well short of the published requirements for a garden community in terms of local job creation and sustainable transport. In its current form the proposal would create a commuter town reliant on existing rail capacity to London, and commuting by private car to existing employment centres in Colchester and further afield. This is in direct conflict with the stated aims of a garden community included in the local plan document.

These transport problems are identified in the sustainability appraisal. Put simply, whilst there may be some potential to deliver sustainable transport along with this development, there is nothing in the local plan to suggest that this would happen. There is no firm plan to increase capacity of the main line railway. There is no firm plan to provide "rapid transit" links to employment centres in Colchester. Colchester and Essex County Council have a poor record on delivering well designed active travel (walking and cycling) infrastructure, and there is nothing in the local plan to give confidence that this would change. In contrast improvements to the A12 have been committed to as part the Road Investment Strategy (see point 6.8 page 27 of local plan). Consultation of improvements to the A120 ended in march 2017 and route improvements may be included in the next round of the RIS. (see point 6.10 page 27 of local plan). The net result will a community divided by two major trunk roads and a major rail line, with no funded sustainable transport options. Given the amount of money that has been spent building bypasses on the A12 around existing towns, to propose a major new town straddling both the A12 and A120 seems remarkably perverse.

I draw your attention in particular to item 6.21 on page 29 of the draft local plan. The proposed provision of jobs within the West Tey garden community is insufficient for a development of this size. Therefore residents will have to commute beyond the boundary of the community for employment. Likely employment opportunities are identified around the University of Essex and London. The plan fails to detail any sustainable travel infrastructure to meet these commuting needs. Given that the only funded travel improvements identified are to the major trunk roads, the net result will be a significant increase in vehicle congestion between West Tey and Tendring, along with increased congestion on the main line railway.

From Policy SP7 on page 40 of the draft local plan I quote paragraph 4. "Each of these will be an holistically .... reducing the need for outward commuting" and point (vi) "Provide and promote opportunities for employment within each new community and within sustainable commuting distance of it". The plan for West Tey fails to meet either of these requirements. There is insufficient space allocated for business, and there is unlikely to be sufficient incentive for business to locate there, given competition from Colchester (including the University of Essex and the proposed Tendring Garden Community) and East London. Therefore residents will have to commute, either across the centre of Colchester, or via train to London. Neither of these is sustainable.

A. The first sentence of Policy SP9 is...
"The adopted policies map identifies a strategic area for development of a new garden community of which the details and final number of homes will be set out in a Strategic Growth Development Plan Document..."

All three of the garden communities policies - SP8+SP9+SP10 - refer to the "adopted policies map" However none of the Publication Draft Local Plans include a map in Section 1 that is designated as an "adopted policies map". As far as can be ascertained this map(s) is not in any part of the Publication draft Local Plans.

B. Although Section 1 is stated as being the same between all three Councils, different maps are presented at different scales for SP9 - in fact for all three proposed garden communities. Many of the maps are half-maps ending at the district/brough borders and the maps have no keys.

The Braintree Publication Draft Local Plan includes two maps relating to the proposed Colchester/Braintree borders garden community:

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

(2) (page 68) Map 10.3. B - Colchester / Braintree borders (1:20,000) - see attached: a purple shaded "half-map" showing the part of the proposed Cokchester/Braintree borders garden community 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.

The proposed garden community appears to be extend further west than is shown in the overview map - extending further into the Parishes of Feering & Coggeshall.

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

C. An "adopted policies map" for the proposed Colchester/Braintree borders garden community is also refered to in the...."HRA Report for North Essex Authorities Strategic Section 1 for Local Plans" May 2017 (Habitats Regulation Assessment Report). No map with the title appears in this document.

The HRA report document contains one map on page 10.. Figure 1: Location of Proposed New Garden Communities - see attached. This map shows the three "proposed new settlements" as red circles / lozenges. The Colchester/Braintree borders proposed settlement is shown lying wholly NORTH of the A120 - which is significantly different from other maps.

Section 1
Section 2 Colchester

See attached representation

Policy SP9 is not sound.
Section E Community Infrastructure is not compliant with the National Planning Policy Framework because it does not mention places of worship. Section 70 of the NPPF states: "To deliver the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: plan positively for the provision and use of shared space, community facilities (such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments."

D7 and D11: A recent survey by Marks Tey Parish Council indicated that the majority of rail commuters arrive by car, and parking is full. The landscape around the road bridge over the railway to North Lane allows for multi-storey car parks to be built from rail level upwards without significant impact on the surrounding views. This would provide additional parking capacity.

F.25: the half a dozen churches in or bordering the Garden Community area would like to help with building new communities, helping govern and support community assets and facilities, and linking with council support workers. This is a genuine offer, based on past and present community engagement, often undervalued; and not for partisan reasons but for community benefit. I am the Vicar of Marks Tey & Aldham.

With its excellent transport links this seems to be an excellent location for a new garden community.

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.

I write to you in regard to the proposed development of a new garden village (West Tey) next to Marks Tey.
Although I sympathise with the need to provide housing for the next generation and the need for different types of housing for those in the community, e.g. bungalows for the older generation, such a large scale development is in complete contrast to what the existing residents of Marks Tey and Colchester may require in the future. At present Marks Tey has approx 1,050 houses and under 3,000 people.
Although extra housing will benefit people, some of whom will be existing local residents, the size of development would mainly benefit people presently out side the area in London and it should be expected that any social housing built would be snapped up by London housing associations for the relocation of people out of London.
Such development will cause the following issues below, such as found presently around Colchester where development has occurred.
Traffic issues
The development at Stanway has already caused regular traffic tailbacks on the old London Road all the way back to the Stanway Garden Centre and the new house building has hardly begun.
The infrastructure in and around Marks Tey is struggling with the usage that it has to cater for. The A120 and A12 which are expected to flank the development areas are often already congested and can not be expected to cater for the traffic generated from any new developments.
The slip road from the A12, south bound, to the Eight Ash Green turn off is very short and extremely dangerous at peak times. The traffic queuing to come off the A12 is often stationary on the A12 for a hundred metres or more.
With the increase in traffic there will be -
- Increased traffic jams
- Increasing pollution (fumes and noise)
- Greater wear and tear on the road surfaces which the A12 at Marks Tey is in dire need of re-surfacing.
The A120 can not be widened without the demolition of a significant number of housing along the route from Marks Tey to Braintree. Merely making some parts dual carriage way will just cause bottlenecks where the road goes back to single lane. I understand that there plans to widen the A12 from Chelmsford to Marks Tey, but it is not clear if the bridges that cross the road are to be rebuilt to allow for the increase width for the entire stretch. If the road is just widened between the bridges bottlenecks will occur at each bridge causing more traffic jams and a greater source of accidents.
The various proposed links between the Braintree junction of the A120 and A12 may give some relief to the A120 between Braintree and Marks Tey, but if the issues with the A12 are not addressed the A12 will be further congested south of Marks Tey. With the extra journey time (both time due to congestion and extra miles) traffic will still use the A120 to get from Braintree to Marks Tey to join the A12 rather than use the A12 and new link road. Only if the A120, between Braintree and Marks Tey, had a reduced speed limit, such as 40mph along the whole stretch would traffic be encouraged to use the new route.
Traffic levels will also be compounded by the extra traffic generated by people living on the developments. Where there is industry, offices and retail units there will be further traffic with some noticeable spikes in usage depending on the type of development. Where there are offices/businesses you would expect increased traffic in the morning and evening as people travel to and go work. However offices would most likely extend the traffic congestion generated by the people going to and from the station. Local workers would travel later in the morning and earlier in the evening, commuters using the railways have a longer journey to work, therefore leave their houses earlier and return home later. Retail units would likely cause an increase during the day with further compounding of traffic levels in the evening for any late night opening.

Who will buy?
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.

A12 to London
Their maybe people that use the A12 to travel each day into London but with the present state of the road and heavy traffic congestion London commuters can not risk the delays in getting to work and use the trains.

Trains
The development at Stanway has already caused regular traffic tailbacks on the old London Road all the way back to the Stanway Garden Centre and the new house building has hardly begun.
The infrastructure in and around Marks Tey is struggling with the usage that it has to cater for. The A120 and A12 which are expected to flank the development areas are often already congested and can not be expected to cater for the traffic generated from any new developments.
The slip road from the A12, south bound, to the Eight Ash Green turn off is very short and extremely dangerous at peak times. The traffic queuing to come off the A12 is often stationary on the A12 for a hundred metres or more.
With the increase in traffic there will be -
- Increased traffic jams
- Increasing pollution (fumes and noise)
- Greater wear and tear on the road surfaces which the A12 at Marks Tey is in dire need of re-surfacing.
The A120 can not be widened without the demolition of a significant number of housing along the route from Marks Tey to Braintree. Merely making some parts dual carriage way will just cause bottlenecks where the road goes back to single lane. I understand that there plans to widen the A12 from Chelmsford to Marks Tey, but it is not clear if the bridges that cross the road are to be rebuilt to allow for the increase width for the entire stretch. If the road is just widened between the bridges bottlenecks will occur at each bridge causing more traffic jams and a greater source of accidents.
The various proposed links between the Braintree junction of the A120 and A12 may give some relief to the A120 between Braintree and Marks Tey, but if the issues with the A12 are not addressed the A12 will be further congested south of Marks Tey. With the extra journey time (both time due to congestion and extra miles) traffic will still use the A120 to get from Braintree to Marks Tey to join the A12 rather than use the A12 and new link road. Only if the A120, between Braintree and Marks Tey, had a reduced speed limit, such as 40mph along the whole stretch would traffic be encouraged to use the new route.
Traffic levels will also be compounded by the extra traffic generated by people living on the developments. Where there is industry, offices and retail units there will be further traffic with some noticeable spikes in usage depending on the type of development. Where there are offices/businesses you would expect increased traffic in the morning and evening as people travel to and go work. However offices would most likely extend the traffic congestion generated by the people going to and from the station. Local workers would travel later in the morning and earlier in the evening, commuters using the railways have a longer journey to work, therefore leave their houses earlier and return home later. Retail units would likely cause an increase during the day with further compounding of traffic levels in the evening for any late night opening.
Utilities
There are also the less obvious issues that go with a large amount of extra housing or businesses for any area. East Anglia is one of the driest areas of the country with rainfall per capita less than the Sarah desert. Water consumption and sewage treatment must be considered, would the existing sewage treatment and water plants in the area, such as in Copford, be able to cope with the excess demands.
Large scale development will also put the local supply of electricity under pressure.

Education and Medical services
At present the local primary and secondary schools are very well subscribed to with limited extra capacity and over all good results from Ofsted. Any development will require further schools to be built to cater for the increase demand and ensure that standards do not fall below what should be expected. Failure to locate the schools within walking distance of the extra housing will result in many children being taken to school by car or with the council supplying a bus service (if parents have to pay for the bus it is very likely that they will drive their children to school). This would result in further traffic and increased pollution during peak times.


Environment
The development plans put forward by the various development organisations have stressed that the environment will be protected and enhanced. In the "Summary-A Vision for Land at Marks Tey" by RF West it mentions there are "No overriding ecological constraints to development" and that "A third of the net work of existing hedgerows on or around the site are classified as "important" in terms of their structure and floral composition". The Land around Marks Tey that is mentioned is a delicate Ecosystem. The hedgerow diversity comes about because of surrounding natural environment. Building thousands of houses will disrupt that cycle, blocking the regeneration of hedgerows and cause wildlife using the hedgerow to be displaced from the areas development which will reduce biodiversity. Pollution levels are very high in the Marks Tey area, both air pollution due to the A120 and A12 and the noise levels from the roads.

The inclusion of a Garden Community at Marks Tey of circa 20,000 homes is ill conceived with none of the concerns raised in early consultations answered i.e.
1. The GC at Marks Tey is in the wrong place for a new town.
2. trunk roads that are congested and highly polluting and have dangerous poor air quality.
3. Station is poorly placed with trains already full.
4. No meaningful public transport planned until 2030.
5. Jobs will be difficult to provide - the councils own consultants cite these difficulties.

This is a very bad plan for the whole area. Trains, roads, schools and healthcare are already under great strain. Another 40,00 cars will ruin air quality even further. I think the fact that we will lose so much of our countryside for a town that will be mainly for commuters is a badly thought out exchange. In a time of austerity how can this plan be affordable and sustainable. When I use the train the station at Marks Tey is difficult to access. The consultants appointed by CAUSE indicate that it cannot cope.

Our full submission explains why the decision to include three new garden settlements in the
Local Plan is unsound, and recommends that two
of the three (SP9 & SP10) should be dropped: http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSE-2017-Part-1-Consultation-response.pdf

We state in this submission why we believe that a Local Plan which include Colchester/Braintree Borders Garden Community ("West Tey") is not positively prepared, justified or effective, and we list why it is in line with national policy. The submission is backed up by the following papers which assess the soundness of the Plan:
1. Detailed amendments required
2. Comments on Sustainability Appraisal
3. New towns: learning from the past
4. Positive vision for north Essex
5. OAN - unnecessary uplifts applied
6. Providing for employment
7. Rail constraints
8. Connectivity & infrastructure
9. Viability: West Tey's business case
10. West Tey: Costs & Risks
11. The deal for land-owners
12. Community engagement

Point 21 only commits to the "Protection and/or enhancement of heritage and biodiversity assets". This is not consistent with the NPPF (paragraph 156), nor the principle outlined in SP7.

CPRE Colchester group considers the West Tey garden community will lead to the loss of significant open countryside, much of it good quality agricultural land. The scale of development is too large and will eventually lead to the effective merger of a number of villages, with the consequent loss of their setting and character.

Further we consider it unlikely sufficient local jobs will be secured and the new settlement will become little more than a commuting suburb.

If development was to go ahead here on anything like the scale proposed major improvements to the A12 and A120, along with capacity improvements to the main railway line are needed before development can begin. The Council can not be certain at this stage that such infrastructure works will be in place in time, if at all in the case of the railway.

- Inadequate infrastructure - No funding or agreed option for improving the A120 which is inadequate for the current population and necessary to this development.
- The location would attract London commuters when the GEML train line is at capacity and no known options to increase capacity. Marks Tey station is also isolated from the settlement. East of Colchester would appeal more to people working in Colchester and the surrounding area.
- Loss of Grade 2 agricultural land when poorer quality land is available east of Colchester - NPPF 112 says priority should be given to lower quality land.
- Not deliverable - Colchester Borough Council has never developed one Garden Community. To try and develop two in the same plan period plus significant infrastructure is a recipe for failure. CBC should focus on the simpler Garden Community first, East of Colchester.

Some of the best and most versatile agricultural land in England will be lost to housing with few employment opportunities for residents. The plan relies on reduced car use but regular public transport will never cover all places people need to go and also to be able to transport items needed for work or leisure. Not all purchases can be balanced on the handlebars of a bike or taken on a bus so more people will turn to Amazon and retailers will go to the wall.

I object to the inclusion of West Tey in the Plan on grounds that it is premature for the following reasons.

The stated factors to be included in the DPD are inevitably aspirational. Moreover, I see substantial difficulties achieving these within the Plan period. Similar concerns were raised in the Kerslake Report.

Employment
While a Garden Community as proposed in East Colchester is based on the existing and expanding Essex University and its Knowledge Gateway, no such base exists in West Tey. There are some small existing industrial and commercial premises in Marks Tey, but it is unclear why this area might be the chosen location for a significant amount of new employment, except that associated with new residential accommodation such as retail and services. It is relevant that there is significant undeveloped employment land allocated previously close to Colchester, which is more likely to be seen by potential businesses as a preferable location.

Transportation
Essex County Council have recently consulted on new routes for up-grading the A12 and A120 truck roads. It is expected that preferred routes will be announced later in the year and known at the time of the Pt 1 Plan Inspection. Although funding for the A12 may be available and work carried out in the 2020 - 2025 period, no funding for the A120 has been allocated in central road-funding programmes. Therefore, although design work may be undertaken on a preferred route for the A120, there is no certainty that construction and completion will occur before the end of the Plan period in 2033. Uncertainties over Brexit and the economy generally add to this doubt.

Development of West Tey is predicated on the realigned A120. Therefore I suggest work, even to define boundaries of the Community cannot proceed on a DPD until this uncertainty has been resolved. Similar uncertainties arise over other vital transport infrastructure, including up-grading the London main line, the provision of the new proposed station, realignment of the Gainsborough line to that station and rapid transit systems to existing centres. All rely to a major extent on national funding programmes subject to the same uncertainties as the road programmes.

Other requirements.
Although not addressed in the policy, there must be similar doubts whether the National Health Service can accommodate and provide new facilities to support such an ambitious Community over the time span envisaged. The worse scenario would be for housing development to proceed within the plan period, before some or all the necessary infrastructure is in place. The whole premise of the Garden Communities is sustainability. Necessary infrastructure in place at the appropriate time is therefore essential, but I suggest, in doubt.

Paragraph 24 refers to appropriate and sustainable long term governance and stewardship arrangements. These matters would be the responsibility of the management bodies established to develop the Communities, known as Local Development Vehicles. Although these have been established outside the planning system, the success of the Communities is bound up with that of the LDVs. These bodies are a new concept to the 4 Local Authorities managing them. I consider the cost structure to develop the GCs is speculative with possible underestimation of some factors and lack at this time, of sufficient professional input. I suggest CBC is over-ambitious in proposing to manage two such bodies at once and that it would be prudent to gain expertise by proceeding with East Colchester, projected to be half the size of West Tey. Then, if other factors dictate, proceed with a further project at West Tey in a future Plan.

If West Tey were dropped from the Plan, it is necessary to find other sites to meet OAH numbers. It is now proposed to site 1000 houses on Middlewick Ranges. Although not brownfield land, it is of less valuable agricultural land than West Tey. The publishes Agricultural Land Classification map (sheet 162) shows that West Tey is mainly Grade 2, very good agricultural land and best and most versatile land, given some protection within the planning system. Now mainly in arable production, it was historically used for seed growing; an indication of it high agricultural value.

Middlewick on the other hand is shown as non-agricultural on the ALC map. However, it is light sandy land running into heavy clay to the south, probably low grade 3 or 4, moderate to low quality agricultural land.

The NPPF at paragraph 112 states, "LPAs should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of ag. land is demonstrated to be necessary, LPAs should seek to use areas of poorer land in preference to that of higher quality"

Following this policy would indicate that Middlewick should be developed first before BMV land at West Tey adding to the argument that proceeding with West Tey is premature in this Plan.

Further weight to this argument arises when one considers that South Colchester is generally less developed than West, North, and as proposed, East Colchester. Developing it would release funding to provide badly needed transport links in this part of the town.

Without West Tey, further housing could be provided in Marks Tey, a designated sustainable village. Following the addition of Middlewick, adjustments were made to previous allocations and these could be reconsidered together with other sites that may have been suggested in the previous consultation.

Support is extended for the identification on the 'adopted policies map' of a strategic area for the development for a new Garden Community for between 15,000 and 24,000 homes, of which the details will be set out in a Strategic Growth Development Plan Document. The area proposed for strategic growth is identified by a red blob, on a simplistic 'Key Diagram', that is not presented on an Ordnance Survey (OS) base. This is not acceptable given the important role that this new community will have to play, not only in the Plan period but beyond. The presentation lacks clarity and creates uncertainty as to the precise boundaries to be allocated or the precise area of search. The housing trajectory states that the new community would come forward from 2023 onwards, i.e. within years 6 - 10 of the Plan period. We submit that this reinforces the need for certainty in terms of site boundaries.

Objection is raised to the proposed delivery of around 2,500 dwellings from the proposed new community within the plan period, without a firm allocation being shown on the Proposals Map.

Failure to identify properly land proposed for the new Garden Community leads to uncertainty and planning blight for years to come. It is submitted that the broad area of search for the new community should be identified on the Proposals Map, with land capable of early delivery in the Plan period being identified as an allocation for a first phase of growth. This would meet the requirements of Part 3 (5) and Part 4 (3) of the Town and Country Planning (Local Planning) (England) Regulations 2012. The Regulations require site allocation policies and allocations of sites to be shown on an OS map that illustrates graphically the application of the policies of the plan, sufficient to guide the determination of planning applications.

Planning Policy Guidance (PPG) accompanying the National Planning Policy Framework (NPPF) confirms in paragraph 002 Reference ID: 12-002-20140306, what a Local Plan should contain. It states:

"The Local Plan should make clear what is intended to happen in the area over the life of the plan, where and when this will occur and how it will be delivered. This can be done by setting out broad locations and specific allocations of land for different purposes: through designations showing areas where particular opportunities or considerations apply (such as protected habitats); and through criteria-based policies to be taken into account when considering development. A policies map must illustrate geographically the application of policies in a development plan. The policies map may be supported by such other information as the Local Planning Authority sees fit to best explain the spatial application of development plan policies."

This advice is consistent with the Council's place-based approach promoted in paragraph 12.1 of the emerging Local Plan for Colchester (Section 2). Yet the plan then fails to adopt this approach by failing to identify land to be developed as a new Garden Community.

Marks Tey already suffers from pollution and air quality issues together with severe severance by the A12, the A120 and the GEML. Shops are severed from the village hall which is itself is severed from the main residential area. The industrial area between road and railway has unsatisfactory and dangerous linkages to both A12 and A120.

West Tey GC is located far from any strategic employment zone and town centre. As a new and stand-alone community, it offers none of the benefits of existing employment associated with the East Colchester GC. It is not a Strategic Economic Area, there is no focus for employment and the level of home-working has not grown appreciably in recent years. Whilst land will be provided locally for employment, it is likely that residents of West Tey GC would be attracted to seek and find work in the established employment hubs (eg North Colchester), which will require travel by car on the A12.

We therefore consider that the West Tey GC is not the most appropriate strategy and is not deliverable. In particular, the essential advance highway and rail capacity improvements are far from certain. Given the current level of congestion and overcrowding, these are essential requirements and need to be in place before development commences. It is also far from certain that sufficient local jobs will be provided in line with the level of housing growth proposed and therefore it is likely that the community will become a commuter dormitory settlement in the open countryside. The location would therefore run counter to the important NPPF principle of reducing the need to travel.

SP9 does not make a good economic case for building a garden community in the West Tey area, as new employment opportunities have not been identified. Just building more industrial units or retail facilities does not mean they will be occupied by thriving businesses.
It is more likely that this development will become a dormitory for commuters. However there is no mention of additional trains, just the possible relocation of Marks Tey station, with no further information on improved road links to stations and increased parking for commuters.
Although provision for further primary care facilities is mentioned, this does not mean there will be sufficient doctors to cope with the additional people. Local medical facilities are already stretched, with people having to wait weeks to see a doctor.
There is no mention of additional police or another police station and local police are already over stretched and under funded.
Affordable housing provides for rented and part owned properties. There is no provision for cheaper homes to buy for first time buyers or people wishing to down size to a bungalow. Garden community properties typically sell at a premium! There is also no obvious consideration of more innovative funding solutions for affordable housing e.g. pension company funding of new residential rentals.
SP9 does not meet the National Planning Policy Framework for sustainable development as it will not protect and enhance our natural environment and by destroying good farmland to make a dormitory town will significantly increase our carbon footprint as there is no mention of moving to a low carbon economy and there is little or no mitigation to compensate for the loss of agricultural land.

No large scale new development should be reasonably contemplated until a new duelled A120 and link road to join the A12 have been completed in accordance with Lord Kerslake's report to Colchester Council. To say at Section 8 that Primary vehicular access to the site will be provided via the strategic network is reckless and unsound prior to these improvements having been made. There is no sound explanation of how sufficient jobs will be provided within the community for such a large scale development for it to be sustainable. In the absence of these opportunities West Tey can only become a commuter town rather than a garden village. The partnership being built by the Council and developers here is overshadowed by the use of L & Q to deliver and finance the residential element and social housing. As London's largest landlord it is difficult to see how Colchester's new home-seekers will not lose out to those moving from London. It is not sound to claim West Tey's raison d'etre is to provide new homes for the next generation of Colchester when it is unlikely that these new homes will be prioritised for local people even if they could afford them. To advocate this size of development within the timescale envisaged appears to me opportunistic when losing such valuable arable land for the windfall profits to the landowners and perhaps the council with a consequential unacceptable increase in air pollution levels.

I object because I think the plan has too many houses in one area in a rural area. I do not object to providing houses for people but think going ahead with the West Tey development in its' current format would be damaging to the people who currently live in this area, the environment and would completely alter the countryside and landscape. Transport systems would not cope. The A120 can hardly cope at the moment with the current population. 23,660 houses in the future and 56,000 more people with about 36,000 extra cars is just too much in one concentrated area. This should be spread over a larger area in Essex. I think the plan to upgrade the station at Marks Tey or move it nearer to the garden community is an idea that really is just not feasible and really think that the railway line, which is already under huge pressure would just not cope. I think that the amount of land being offered to the new garden community is far to big. I have lived here all my life and cycle and walk around these areas daily. The whole rural way of life and landscape would be changed; this is the thing I find most upsetting. I also think your way of asking us local people in the community to respond online is not at all helpful in that it is difficult to access and not at all accessible - especially when this is so important to all of us who live in the community. I work for Essex County Council and understand the importance of communicating clearly and making consultations easy for people to access - this consultation is extremely difficult to comprehend and take part in. Many of us in the community are very concerned about the road infrastructure which is almost crippled now and can see many years ahead of half completed roads and schemes but more and more houses being built. Also I question whether there is a real commitment from developers to build schools, GP Surgeries, and healthcare centres and also places of worship. I understand there are no specific commitments to build places of worship for a new town where there could possibly end up being 26,000 houses and at the moment there may only be a vague commitment to allowing church groups and religious groups to have use of a community building. There should be a much greater level of awareness for people's spiritual well being and I hope this will be looked at further in future planning meetings with the 120 Gateway Group.

Leaving Colchester via non-A12 route Marks Tey is the first place on the A120 to have farmed fields.

I feel this marks the edge of rural Essex and should not be built on in vast numbers in order to keep the identity of the existing 'villages' and thus ensure the preservation of the nature of Essex County.

Also, until the new A120 is built many choices will not be available to comment on and traffic flows will only be projections like those for the M25 and in particular the Dartford Crossing.