Introduction

Text needs to be updated to reflect adoption of the new Essex and Southend-on-Sea Waste Local Plan in July 2017.

Change by replacing the first two paragraphs (retaining the third paragraph unchanged) as follows:

Essex County Council is the waste planning authority for the Borough, and is responsible for preparing planning policies, and also for assessing applications for waste management development. The Essex and Southend-on-Sea Waste Local Plan (2017) is a statutory Development Plan which should be read alongside the Colchester Local Plan. It sets out where and how waste management developments can occur, and is the planning policy against which waste management development planning applications are assessed.

The Waste Local Plan allocates new waste development at Bellhouse, Stanway; Fingringhoe Quarry and Wivenhoe Quarry. It also identifies Areas of Search to meet the need for additional small scale waste management facilities. These Areas of Search are existing industrial estates within the Borough, and are located away from residential and other uses sensitive to amenity impacts such as schools, retail, leisure and office development.

This representation applies to 'County Level Plans' and the 'Essex Local Transport Plan'. A change is required to provide a context to the Local Transport Plan and state ECC is the Local Highway Authority and Local Transport Authority.

This representation provides a context to the other representations made by ECC to the Publication Draft Local Plan. The North Essex Authorities (Braintree, Colchester and Tendring) have worked collaboratively with ECC throughout the preparation of Section 1 and 2 of each Local Plan. ECC is a signatory to the 'Memorandum of Co-operation: Collaboration on Strategic Priorities in North and Central Essex', which has enabled the joint working on cross-boundary strategic priorities and matters through North Essex districts, and Chelmsford City Council. This has covered matters regarding ECC's role as Minerals and Waste Planning Authority, Local Education Authority, Highway Authority, Lead Local Flood Authority and lead advisors on Public Health. This has also included collaborative work in progressing the potential for three Garden Communities in North Essex to provide for growth in, and beyond the plan period.

In responding to this consultation, ECC has ensured its representations and on-going engagement with CBC has addressed the ECC's areas of responsibility consistent with national policy to enable sustainable development. The ECC response to the Draft Publication Plan identifies several areas where clarification is sought to enable effective delivery and amendments to improve policy and explanatory text. ECC will work cooperatively with CBC regarding our statutory roles (indicated above) and as a partner in the North Essex Garden Communities to ensure issues can be positively addressed prior to the submission of the Draft Publication Plan for examination. ECC would look to prepare a Statement of Common Ground with CBC to address the issues raised.

Soil and land quality
There is still no policy on the protection of soils and consideration of best and most versatile agricultural land. Therefore we reiterate our previous advice on soils. Natural England advises the inclusion of a policy which aims to protect soil quality during development to protect good quality land and to protect the ability of soil to allow water penetration by avoiding compaction, should be undertaken.

The Plan should recognise that development (soil sealing) has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process. The Authority should refer to the Defra Code of practice for the sustainable use of soils on construction sites. Please see Annex 1 for further details on Soils.

Best and Most Versatile Agricultural land (BMV)- The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with paragraph 112 of the NPPF.

We therefore advise that the plan take a holistic approach to the assessment of sustainable development sites in respect of agricultural land quality. We recommend the inclusion of a specific Policy on Best and Most Versatile Agricultural Land. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services. In the longer term, protection of BMV land may also reduce pressure for intensification of other land.

Officer NB: Please see summary for appropriate summary for each rep. The full representations submitted are attached to all representations on JDi (The consultation portal).

The attached representations are submitted on behalf of Andrew Mattin, in relation to his land at Livelands, Marks Tey.
The following documents have been submitted:

Representations on the Publication Local Plan Statement, and this has also been split into the relevant response forms for ease of reference:
o Response Form General
o Response Form SG1
o Response Form SG2
o Response Form SG8, SS11 and the Sustainability Appraisal
o Response form SP2
o Response Form SP3
o Response Form SP7 and SP9
o Response Form Vision
o Sustainability Appraisal Comment Form
 Copy of correspondence to CBC regarding the SHLAA (dated 14th September 2016)
 Additional evidence relating to the site access:
o Road Safety Audit Stage 1
o Request for Road Safety Audit
o Designer Response by Create Consulting Engineers Ltd
o Site Access Arrangements Existing
o Site Access Arrangements Proposed
o Correspondence with Essex County Council
If you require any further clarification on the above please let me know. I would be grateful if you
could confirm receipt.

Officer NB: Please see summary for appropriate summary for each rep. The full representations submitted are attached to all representations on JDi (The consultation portal).

The attached representations are submitted on behalf of Andrew Mattin, in relation to his land at Livelands, Marks Tey.
The following documents have been submitted:

Representations on the Publication Local Plan Statement, and this has also been split into the relevant response forms for ease of reference:
o Response Form General
o Response Form SG1
o Response Form SG2
o Response Form SG8, SS11 and the Sustainability Appraisal
o Response form SP2
o Response Form SP3
o Response Form SP7 and SP9
o Response Form Vision
o Sustainability Appraisal Comment Form
 Copy of correspondence to CBC regarding the SHLAA (dated 14th September 2016)
 Additional evidence relating to the site access:
o Road Safety Audit Stage 1
o Request for Road Safety Audit
o Designer Response by Create Consulting Engineers Ltd
o Site Access Arrangements Existing
o Site Access Arrangements Proposed
o Correspondence with Essex County Council
If you require any further clarification on the above please let me know. I would be grateful if you
could confirm receipt.

I would like to repeat and reinforce my objection to the proposed plans for development of 40 homes (now reduced to 30) off New Barn Road, Great Tey, originally submitted on 18th April 2017.
As previously stated, I have lived in the village for the past 22 years in our family home which backs on to the proposed site for development, choosing to pay the premium to allow us to live in the countryside in a quiet village environment where we have brought up our two children. We have invested heavily in our home, extending and making improvements to meet the changing needs of a growing family and enjoying all aspects of village life.
However, these proposed plans, if given the go ahead, would change everything.
The thought of a 30 house development overlooking our small back garden is unthinkable. We are situated on the edge of the village envelope which we have always been led to believe would not be extended beyond and indeed, other applications outside the envelope have been rejected by the Parish Council including this site on two previous occasions. I am therefore at a loss as to why this late proposal can now be submitted for consideration? And would like to know what has changed to make it a viable option now given the previous rejections?
It would mean a complete change of lifestyle for us in terms of loss of privacy, lost views, lost environment, adverse impact on surrounding conservation areas and green space, increased traffic through the centre of our village and through our road in particular, increased pollution, increased noise levels, possible unwanted street lighting and difficulties parking. Not to mention devaluation of our property and the prolonged disruption and impact on our daily lives during the construction phase.
Over the years, I have witnessed for myself the increased traffic on our single track lanes as frustrated drivers seek alternative routes to work or home to avoid the ever increasing delays caused by volume of traffic and hold ups on the A120 and A12.
Add to this the increased pressures on our local railway services, schools, shops, hospitals, doctors' and dentist surgeries and it is a recipe for disaster.
Fortunately, we know from local residents' meetings and Parish Council meetings held as a result of this planning proposal, that all our close neighbours and a resounding number of other villagers agree that the site proposed is unsuitable and that the proposed development is too large and unsustainable with the impact it would have on the present local infrastructure and other services and amenities.
Great Tey Parish Council and Local Councillor, Peter Chillingworth also uphold this view and have made their objections known to the Borough Council in person and in writing.
It is my understanding that an alternative site for development of 17 (now reduced to 10) houses in Brook Road has already been accepted by our Parish Council for submission to planning and that this would meet the recommended rate of growth for this area at this time. Again, at the meetings held locally, many of those present agreed that this development was largely acceptable to them.
This latest proposal appears to have been submitted 'under the radar' at a late stage in the process and has therefore stirred up a lot of mistrust and ill feeling among residents. There is a real strength of feeling that we, the village residents, should be listened to and that the 30 house development is grossly inappropriate for the needs of this village.
I do appreciate that our villages are under scrutiny to provide areas for housing development where people would like the same opportunity to enjoy living in the countryside in a village setting. However, this should not be to the detriment of people already living there who have invested heavily in their homes, their local community and the surrounding environment over many years.
We chose to move and live in the countryside 22 years ago so that we could enjoy a certain quality of life for which we have paid and continue to pay premium rates for. If this development goes ahead I will essentially be living in the middle of a housing estate where I do not choose to live nor wish to remain. To move away would incur considerable financial and emotional loss which could not be compensated for.
I strongly feel that residents of long standing such as ourselves, should be given equal consideration in the balance of things when planning new developments and I strongly feel that we have not been given that opportunity in this case. I trust that the Borough Council will give this view their serious and due consideration when approving new sites for houses.

In conclusion, I would like to add that I do not consider the Local plan to be legally compliant, sound or to comply with the duty to co-operate. My reasons for this are due to the late submission of the proposed planning site off New Barn Road which has not allowed for a full and proper consultation period. The site is outside the village envelope where only recently the Parish Council rejected a new build for this very reason. And finally, because planning on the proposed site has been rejected and refused twice before.

Since I have found your portal impossible to use I would be pleased if I could have written confirmation from yourselves that my objection will be logged onto the portal system and counted as an objection against the above proposed development plan.

WEST TEY
Housing
Low cost housing needed for local people
Jobs
No local industry therefore no jobs for new people coming in.
All working people will have to commute
Railway network
Already at full capacity with only one track in each direction thus limiting number of trains.
Schools
New schools will be needed for influx of children, teacher recruitment already a problem.
Doctors
Already difficult to recruit GPs so additional strain on existing services
Hospitals
Colchester Hospitals are already struggling to recruit doctors and nurses and are working at capacity
Funding for services
Local authority already under strain to provide adequate services for existing community

Roads
Tiptree to A12 - improvement mentioned. B1023 is already up to capacity with traffic and dangerous for users and local community.

Colchester Borough Draft Local Plan is unsound in its present form because it has not included a robust prescriptive policy for Monitoring Enforcement and Punishment ( Penalty) and non adherence to conditions and obligations imposed by Colchester Borough Council Planning Authority on permitted and approved development.

In our opinion the Local Plan as a whole is Unsound because
1. It has failed to address the relative sustainability of Colchester compared with other parts of Essex that are closer to the employment source. The proposed additional dwellings for Chelmsford is 805pa and 920 at Colchester - an extra 14%. The reverse should be the case as Chelmsford has a far superior road network with much easier connection to trunk roads and motorways ,closer to London and has a less restrained town centre.
2. The outcome of the Brexit is unclear but immigration from the EU is already falling and new housing needs will ease.
3. The current proposals would help create 30 miles of continuous urban sprawl from the University of Essex to the West of Braintree and this is against all policies.
4. In regard to Copford the plan fails to the test of proportionality - 12.7 (P72)

Existing Commitments New Population 2011 (Wikipedia)
Copford 0 120 1689
Gt.Horkesley 0 93 2476
West Bergholt 0 120 3344
West Mersea 0 200 7183
Wivenhoe 250 7637

West Bergholt has the same allocation yet is double the size and has a doctor's surgery, pharmacy, supermarket, large convenience store, post office, 3 pubs, and a hairdresser. Cop ford has only a partial shop.
5. There has to date been insufficient interaction and consultation with Copford under the localism Act 2011 see CBC plan 1.11 and 12.83. The failure lies with the former Copford Parish Council who set up a Neighbourhood Plan Review Group and then disbanded it. The group formed VOICE ( Village opinions in Copford and Easthorpe) continued the work,
Organised a public meeting with over 125 residents in February 2017 with local Councillors and Senior Planning Officer and submitted a Neighbourhood Report in April.
There is election on August 2017 for vacancies and it is understood the intention is or the Parish Council to now endorse and enhance the report by VOICE to gain more influence and control as per Eight Ash Green, Tiptree, West Bergholt and Wivenhoe (See 12.87)
6. The location and impact of additional housing at Marks Tey is unclear with suggestions that it could extend to the Copford Borders, the date of the proposed road changes that might justify West Tey will undoubtedly slip. The CBC plan has a suggestion that Marks Tey station might be moved in order to service West Tey. This unlikely suggestion would diminish the sustainability of Copford.

The allocated sites in Copford are unsound because:

A. Hall Road for 50 dwellings because:
* On highway grounds there is insufficient visibility at the junction of Hall Road with London Road.
* Hall Road is an attractive historic Iron Age road and apart from a short section is narrow and an important landscape feature providing distinctive character to the village. Development would not conserve and enhance the natural and historic environment including landscape-Policy S6
* Fails to recognise the need for protection and/or enhancement of heritage and diversity assets and the habitats along the Roman River corridor (SP9) Hall Roads form one boundary of the Roman River Valley and is part of the Roman River corridor.
* It would impact on the Local Wildlife site of Pitts Wood
* Contains important archaeological remains
* It is a productive Greenfield site and and on 4th August produced 4tons of wheat an acre whereas the section near the Village Hall was not expected to yield more than 2.5 . The National Policy is that Greenfield sites should only be used if there are no alternatives- this is not the case.
* Safe access to the school via London Road and School Road far in excess of the suggested 800m maximum walking distance to a primary school
* Outside walking distance of Marks Tey Station
* Copford is largely a ribbon development village and such development would harm intrinsic character
* It would infringe the stated aims of CBC at sports provision 15,14,1.79,15.85. The lows together with Hall Road and the footpath between 43 and 45 London Road provide a high amenity value to residents of Copford and also the surrounding villages and is used on a daily basis by a significant number of recreational users. This is confirmed by the petition collect by 84 year old Jan Whitehouse.
* Part of the site at the North West corner has flooded on several occasions.
B. The site at the end of Queensbury Drive ( not in the call for sites) for 70 dwellings is unsound:
* The access road is of insufficient width for the number proposed
* Difficulties for residents during construction stage

The Plan could be made sound and provide adequate housing if:

* There was better access to Queensberry Drive see points below
* Made an allowance for Copford Place- an important Grade 2 10000sq ft listed building at risk, in several acres within the village envelope with the benefit of an outstanding consent for 12 additional dwellings. Appears to have capacity for at least 25-30 units of accommodation
* Acknowledge windfall sites. There have been 23 new dwellings in the last 4 years, 10 since the initial plan was published- none were in the previous plan. The former Police Station has an application for a change of use.
* Give full regard to the use of Brownfield sites. It is inevitable that during the length of the plan that some of the poor quality commercial buildings in London Road will be redeveloped residentially and this could be encouraged by moving the envelope to the extent of their boundaries.
* A re-examination of other sites offered- notably the eastern part of the Car boot site- a Brownfield site that was excavated for sand and gravel for the construction of the A12 Stanway by pass in the 1960`s. The landowner has offered to enhance the separation from Marks Tey by landscaping and planting. It is within walking distance of the station, would not impact on the character of the village could also be the access route to the land at the end of Queensbury Drive along with the offered site at the end of Foundry Lane
* Sites in School Road such as a smaller part of the site to the left/north of the village hall, it is a short distance from the school and still accessible to London Road buses.
* Small sites, even in the Copford Green area that would reduce the imbalance within the village providing more organic and diverse growth.
* A clear indication of what S106 agreement conditions could be enforced that would bring very specific benefits for the village amenities as per recent approvals at Elmstead in Tendring

Yours faithfully
Andrew and Joy Waters.

* Officers note: Submitted with 1163 people on the list of those being represented by STOP350.

PLEASE NOTE: Supporting Documents including the full representations with redacted personal information is attached.

__________________________________________________________________

OBJECTION TO THE DRAFT STAGE OF THE COLCHESTER BOROUGH LOCAL
PLAN 2017-2033 (DLP) JULY 2017 - BY STOP 350 (THE GROUP)
Brief Summary: The objection of the Group is that the Draft Local Plan does not recognise that Mersea is an Island with restricted access due to it's single tidal road. Also the limited room for expansion for future generations, with the whole Island lying within the Coastal Protection Belt. Also the omission of constraints, transport issues, incorrect housing data and the lack of capacity for Medical care on the Island. It is the submission of the Group that the DLP is unsound in respect of its proposals for 200 new dwellings in West Mersea and Caravan Parks on Mersea Island. Part A of this submission document summarises each concern. Part B details each concern with reason and evidence. Also Appendix A, B & C. The group would also like to make a presentation to the Inspector at the hearing into the Local Plan.