Policy SG3: Economic Growth Provision

Showing comments and forms 1 to 14 of 14

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6140

Received: 23/07/2017

Respondent: Mr Sean Pordham

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

no clear strategy where the jobs will come from regarding the GC at Marks Tey. Specifically the strategy does not state what measures will be put in place to encourage the amount of jobs required to sustain a GC the size of the one being planned at Marks Tey.

Full text:

S Pordham

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6167

Received: 08/08/2017

Respondent: The University of Essex

Agent: The JTS Partnership LLP

Representation:

Whilst it is for the Borough Council to determine the exact level of new employment land that needs to be identified, in order to meet the economic requirements of the Borough throughout the Local Plan period, the University supports the general thrust of the policy and the identification of both the Knowledge Gateway / University Strategic Economic Area, and the Tendring Colchester Borders Garden Community, as strategic employment locations.

Full text:

Whilst it is for the Borough Council to determine the exact level of new employment land that needs to be identified, in order to meet the economic requirements of the Borough throughout the Local Plan period, the University supports the general thrust of the policy and the identification of both the Knowledge Gateway / University Strategic Economic Area, and the Tendring Colchester Borders Garden Community, as strategic employment locations.

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6306

Received: 04/08/2017

Respondent: Marks Tey Church

Representation:

It seems a shame that the Colchester Braintree Borders GC expects so little Economic Growth Provision. It will have even better access to road and rail links than Stanway SEA, and would seem ideally placed for new facilities such as Shopping centres, Distribution centres, Police, Fire, Ambulance, and even a Hospital or medical facility.

Full text:

It seems a shame that the Colchester Braintree Borders GC expects so little Economic Growth Provision. It will have even better access to road and rail links than Stanway SEA, and would seem ideally placed for new facilities such as Shopping centres, Distribution centres, Police, Fire, Ambulance, and even a Hospital or medical facility.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6519

Received: 09/08/2017

Respondent: Dr Alan Drew

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

There is little meat to the plan for economic development. What will CBC do to increase local employment to support 30k houses? Asking these questions of the politicians revealed they had no plan, so the houses will be London overspill, which will result in additional strain on an already overcapacity service. No plans are present to improve the trains such that they can carry a further 10k-20k of people to jobs in London, Chelmsford etc. To put it into context, each 12 carriage train can hold about 1200 people, so this would mean an extra 10+ trains each rush hour.

Full text:

There is little meat to the plan for economic development. What will CBC do to increase local employment to support 30k houses? Asking these questions of the politicians revealed they had no plan, so the houses will be London overspill, which will result in additional strain on an already overcapacity service. No plans are present to improve the trains such that they can carry a further 10k-20k of people to jobs in London, Chelmsford etc. To put it into context, each 12 carriage train can hold about 1200 people, so this would mean an extra 10+ trains each rush hour.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6635

Received: 11/08/2017

Respondent: Mersea Homes

Agent: Mr Brian Morgan

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The University of Essex is a successful top ranked institution which makes a major contribution to the local economy. In addition to the Knowledge Gateway expansion more provision is needed for University private sector partner organisations. In addition, a key target is to retain a much higher percentage of postgraduates within Colchester, many of whom will have new start-up companies of will have out grown the Knowledge Gateway. Accordingly up to 7ha of land to support a research park is proposed.
*Officer Comment; Tracked version of Local Plan submitted attached in supporting docs for this representation.

Full text:

The University of Essex is rated amongst the top Universities in the UK and is currently undergoing a 50% expansion programme and it is estimated adds £478m to the UK economy. The proposed 7ha expansion of its Knowledge Gateway in the local plan will allow increasing numbers of academics to set up new research based companies which will be a significant part of the economic prosperity of north Essex. Currently only 3% of Alumni stay in the area after graduation and the University is seeking to increase this figure significantly. In addition to the Knowledge Gateway expansion the local plan proposes a further 2.8ha of B1a/b use which will deliver 11,276m2 of floor space. The Knowledge Gateway itself is University owned facility leaving just 2.8ha of technology / business park type accommodation to be shared by post graduate start up organisations / Knowledge Gateway overspill with the private sector. We believe this figure is too low and will stifle knowledge based economic growth. The University will depend on sufficient land being made available for private sector partner organisations to move close to the University. A recent conference held at the University discussed how business / research parks depend on the hub concept where multiple organisations feed off each other's innovation and technology. Whilst the forthcoming development plan document will detail how the private sector will be encouraged to build their own accommodation we believe it is necessary to increase technology / business provision at this stage of the plan process. Accordingly, we propose that the 2.8ha of B1a/b land proposed for the Tendring Colchester Borders Garden Community should be increased up to the 7ha allowed for the Knowledge Gateway expansion. This would bring the total Strategic Economic Area to a possible 14 ha.

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6775

Received: 11/08/2017

Respondent: Braintree District Council

Representation:

BDC supports CBC's economic aspirations and chosen locations for new employment land.

Full text:

BDC notes that Colchester will allocate employment land sufficient to meet 44.2ha of new employment land which is between the economic scenarios for the EEFM (29.8ha) and Higher Past Completion Rates (55.8ha) requirements as specified in Colchester's 2015 ELNA. This is towards the higher end of a range of scenarios given in the ELNA; a land requirement of between -21 and 55.8ha is suggested. Similarly, BDC is pursuing a 'high' growth scenario which equates to growth of 30.5 hectares plus the replacement of recent losses. We are confident that there will be sufficient employment land allocated to meet employment needs and provide sub-regional competition. BDC support the Strategic Economic Areas (employment allocations) at Stanway, North Colchester and the Knowledge gateway, these locations are accessible with good road connections to Braintree District.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6804

Received: 11/08/2017

Respondent: Marks Tey Parish Council

Agent: PJPC Ltd

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation:

it is noted that this policy makes reference to 4.5 hectares to come forward through the Garden Communities; this should be referenced in the main policy (SP2) to give clarity.

Full text:

it is noted that this policy makes reference to 4.5 hectares to come forward through the Garden Communities; this should be referenced in the main policy (SP2) to give clarity.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6871

Received: 18/08/2017

Respondent: Martin Robeson Planning Practice

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Officer summary -Excessive amount of employment land allocated. The supply is some 2.5 times what is required. Lower need figure of 22 ha from 2015 ELNA should be used. Flooding the market with employment land does not necessarily reduce the price and render sites more viable. Stanway and in particular Stane Park has significant barriers to deliver including infrastructure costs and limits on types of occupiers that would consider the site suitable. Worked example provided on employment land requirements.

Full text:

Paragraph 21 of the NPPF states that local planning authorities should "set criteria, or identify strategic sites, for local and inward investment to...meet anticipated needs over the plan period". It only requires a quantum of land to be identified to meet anticipated needs, and does not require an LPA to provide an oversupply or a "buffer" of sites over and above this. Whilst it is recognised that one must allow for choice and flexibility in the market, here there would be a "buffer" of 100% or more. We don't know what a suitable buffer may be to provide for choice and flexibility, but would argue that a buffer more than double the anticipated needs in an inefficient and unsustainable use of scarce land resources.

The lower of these figures, 22 hectares, comes from NLP's ELNA 2015 study reflecting the baseline job growth figure, which we argue is the most accurate scenario and accurately reflects needs. The Council is also reminded of its position when deciding on the resubmitted Tollgate Village application in late 2016 following the appeal decision for Stane Park Phase 1, where it accepted that take-up of employment land is circa 1 hectare per annum, and therefore a supply of 22 ha provides a more than adequate supply of land for the plan period.

The figures in Table SG3, informed in part by Lichfield's Employment Land Supply Delivery Trajectory (May 2017) includes sites that have a total combined supply of double the identified requirements. However, in fact when the worked example below is taken into consideration, the requirement numbers are incorrect, so the supply is some 2.5 times what is required.

The take-up of employment land is qualitative and very location specific. Businesses will go where they want to go, according to occupier demand, supply chains, access to the markets etc. Flooding the market with employment land does not necessarily reduce the price and render sites more viable. Stanway, and in particular Stane Park, as the Council is well aware, has significant barriers to deliver including significant infrastructure costs and a growing residential neighbouring site to the west, which not only affects the viability of bringing forward the site for employment purposes but also limits the types of employment occupiers that would be consider the site suitable for its purposes.
Worked Example
76,000 sq.m of office floorspace is required (Lichfield's 2017 Trajectory):
- If 60% is in lower density business park developments at a plot ratio of 0.4, then 45,600 sq.m on 0.4 uses 11.4 ha of land.

- If 40% is in higher density town centre locations at a plot ratio of 2.0, then 30,400 sq.m on 2.0 uses 1.52 ha of land
Therefore the total land requirement is 11.4 + 1.52 = 12.92 ha, compared with the proposed supply of 24.5 ha (Appendix 2 in Lichfield's 2017 Trajectory) or 15.4ha as at Table 6.13 (paragraph 6.62) of NLP's ELNA 2015
However, a plot ratio of 0.4 is that applied to industrial (B1c/B2/B8) development. It produces a single storey building covering 40% of the site. Applied to offices that would be an enormously land hungry way of making provision and thus unsustainable. Co- incidentally, the undeveloped part (60%) could provide parking at a ratio of 1 space per
16.67 sq.m (using the site planning convention of 1 space needs the equivalent of 25 sq.m in aggregate).
A plot ratio of only 0.8 (rather than 0.4 for "business park" development), would halve this part of the office requirement from 11.4 ha to 5.7 ha.
Then, the total land requirement to accommodate office floorspace identified needs would be 5.7 + 1.52 ha = 7.22 ha.
So a total of 7.2 ha required instead of 15.4 ha (NLP 2015) for offices (compared with a supply of 24.5 ha, i.e.: more than 3 x).
Making the total land requirement 7.2 + 6.6 (but now in 2017 a negative, at best 13.8 ha) = 15.2 ha rather than 22 ha (in Table 6.13, NLP 2015).

Attachments:

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7029

Received: 29/08/2017

Respondent: Andrew Granger & Co.

Representation:

Support the allocation of employment land within the Colchester Borough and the identification of 3.5ha of land to be allocated at the Edge of Colchester Town Centre. In particular, we fully support the allocation of 2.3 ha of Land at Place Farm/Whitehall Industrial Estate as indicated within the May 2017 Employment Land Trajectory. As previously stated, we believe that the Land at Place Farm has sufficient capacity to accommodate 2.3 ha of employment land, which could provide up to 9,200 square metres of new floor space. *Continued in full text

Full text:

1. Introduction

1.1. Andrew Granger & Co. Ltd specialises in the promotion of strategic land for residential development, commercial and employment uses through the Local Plan process.

1.2. On behalf of the Trustees of the S A Meller Estate we are seeking to work with Colchester Borough Council in promoting Land at Place Farm, Rowhedge Road, Colchester (Appendix
1) for residential and employment development uses.

1.3. This document provides a written submission to the Colchester Borough Local Plan 2017- 2033 Publication Draft Consultation and is framed in the context of the requirement for the Local Plan to be considered legally compliant and sound. The tests of soundness are set out at Paragraph 182 of the National Planning Policy Framework [NPPF], which state that for a development plan to be considered sound it must be:

- Positively prepared - the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

- Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

- Effective - the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

- Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

1.4. This submission supports the proposed allocations at Land at Place Farm, Rowhedge Road, Colchester for employment and residential uses as identified in the Proposals Plan and also promotes additional adjacent land for residential development.




















P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 4

2. Site Appraisal & Context

2.1. The proposed development site has a total site area of approximately 5.97 ha (14.7 acres) and is located on the south-eastern edge of Colchester and accessed off Rowhedge Road, as shown outlined in red in Appendix 1.

2.2. The site consists of a single field of pasture land with clearly defined boundaries marked by mature hedgerow to the north, south, east and west. The site is bordered to the north and east by the Whitehall Industrial Estate (including the Colchester Sewerage Treatment Works), to the west by residential properties and to the south by further agricultural land.

2.3. The site is located in close proximity to a number of services and amenities, which are located approximately 0.4 miles from the site entrance on Old Heath Road which is identified as a Local Centre in the Plan. Services include Old Heath Congregational Chapel, Old Heath Community Primary School, Co-Op Food Store and a number of small, independent coffee shops and retailers. The Whitehall Industrial Estate, which is located adjacent to the proposed development site, also provides a number of employment opportunities. Businesses located at the estate include Gallery Bathrooms, Nash Bathrooms, Maple Tree Cars and Colchester Dairy.

2.4. There are further services and employment opportunities available in close proximity to the site in Colchester Town Centre (approx. 1.9 miles), Rowhedge (approx. 1.2 miles), Fingringhoe (approx. 2.1 miles), Wivenhoe (approx. 2.3 miles) and Abberton (approx. 3.7 miles).

2.5. In addition, the site is well served in respect of public transport links with the nearest bus stop located next to the site entrance on Rowhedge Road. This stop is served by the 66(A/B) bus service which runs between West Bergholt and Rowhedge via Colchester with services stopping at Rowhedge Road approximately once an hour between 7am and 7pm from Monday to Saturday.

2.6. We consider that the site has the capacity to accommodate a mix of residential and employment land uses, as follows:

2.6.1. It is considered that the allocated site, identified red on the Proposals Plan and blocked red at Appendix 2, and the adjacent land (blocked green at Appendix 2) could facilitate the development of approximately 100 dwellings including pedestrian links, public open space, car parking, landscaping and drainage. Any proposed development scheme would provide a range of property types and sizes, including a proportion of affordable housing, subject to viability.

2.6.2. The site also has the capacity to accommodate approximately 2.3 ha of employment land (shown blocked purple at Appendix 2), which could provide up to 9,200 square metres of new floor space, associated car parking, facilities and landscaping, which would complement the existing Use Class B employment land uses at Whitehall Industrial Estate.



P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 5

2.7. Any development of the site could be sensitively designed to protect the residential amenity of the neighbouring residents to the west of the site, by retaining the existing hedgerows and matures trees around the site boundary, and enhancing those boundaries with significant additional planting. Furthermore, any development scheme would give consideration to balancing the demands of the proposed residential land use in comparison to the existing and proposed employment land uses; to ensure that all land users enjoy an appropriate level of amenity.

2.8. Therefore, we consider the site to be in a sustainable location, close to a number of services and facilities and highly accessible. It provides a good opportunity to make a valuable contribution towards meeting the Borough's development needs.













































P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 6

3. Comments on the Colchester Local Plan Publication Draft Document
3.1. On behalf of the Trustees of the S A Meller Estate we wish to make the following observations on the Colchester Local Plan Publication Draft Consultation. Overall, we agree with the vision and objectives set out in the Draft Local Plan, however, to ensure that the plan is robust and provides for flexibility, we make the following comments.

Section 1: Shared Strategic Plan

3.2. In respect of Policy SP1: Presumption in Favour of Sustainable Development, we strongly support the inclusion of this policy in the Colchester Local Plan in line with Paragraph 14 of the National Planning Policy Framework [NPPF]. We are encouraged by the Council's desire to positively consider proposals that contribute to the sustainable development of Colchester and North Essex.

3.3. We support the proposed spatial strategy for growth set out in Policy SP2: Spatial Strategy for North Essex. The NPPF and the Draft Local Plan are underpinned by a 'presumption in favour of sustainable development'. It is therefore considered rational to direct development towards locations that are accessible and are within close proximity to a wide range of employment opportunities and local services and facilities.

3.4. With regards to Policy SP3: Meeting Housing Needs, we fully support the flexibility provided by the recognition that the development requirements outlined in this policy are a minimum and the positive approach to development proposals outside of the Local Plan allocations, where they support the overall spatial strategy. We consider that the land at Place Farm, Rowhedge Road has sufficient capacity to deliver up to 30 dwellings, which would provide a range of dwelling types and sizes and contribute towards meeting the identified housing needs for the Colchester Borough.

3.5. We fully support the flexible approach to employment and retail development shown in Policy SP4: Providing Employment and Retail. In particular, we support the flexibility demonstrated in relation to the quantum of development across the plan period through the use of baseline and higher growth scenarios. However, in order to ensure the plan has a robust approach towards the provision of employment and retail land, we believe that it is important for the policy to clarify that the baseline development levels are a minimum requirement. This will ensure that the Borough provides the level of employment and retail development that is necessary to deliver the jobs required to sustain the anticipated population growth. As previously stated, we consider that the land at Place Farm, Rowhedge Road has sufficient capacity to deliver up to 2.3 ha of employment land which would contribute towards meeting the identified needs for the Colchester Borough.

3.6. In respect of Policy SP6: Place Shaping Principles we fully support the recognition that good planning and good design are inseparable in line with Paragraph 56 of the NPPF. The proposed development scheme for the subject site could be designed with consideration



P/300/15.1 - Land at Place Farm, Rowhedge Road, Colchester 7

for all of the criteria contained within the policy; the proposed development site could be designed in a manner that respects local character and context and ensures that it enhances the quality of the street scene, any scheme would seek to retain a significant proportion of the trees and hedgerows that bound the site and a large amount of additional planting could also be provided to ensure that the residential amenity of neighbouring properties to the west and future residents of the site is not adversely impacted. Furthermore, sufficient space would be provided on-site to allow for off-street car parking for all proposed dwellings.

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7121

Received: 05/09/2017

Respondent: G120, Cirrus and L&Q

Agent: Iceni Projects Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The target of the Councils to the provision of one job to every household within the garden communities ... is strongly supported... It is with this target in mind that we feel the employment land allocation figure for Colchester Braintree Borders GC stated within Table SG3 of Section 2 of the Local Plan targets an under-provision for what would be delivered on the site.

Full text:

see attached statement

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7127

Received: 05/09/2017

Respondent: Hopkins Homes

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

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

Full text:

See attached response forms

Given the similarity of the policy with the previous version, my client repeats the previous concerns raised regarding the overly prescriptive elements contained within this policy. The second bullet point requires all new development to exhibit individual architectural quality within well considered public and private realms. This is a vague statement that taken to extreme could impose an unnecessarily high level of design quality that may not be appropriate to either the scheme or the area. The design requirements of the NPPF are adequately addressed in the first bullet point of this policy. The sixth bullet point requires the enhancement of the public realm through the provision of specified measures. This may not be appropriate or possible in all cases and as such the policy is unnecessarily rigid. The eighth bullet point assumes that all development will provide parking facilities. This may not be the case. For example, some development proposals may involve sites that are already adequately served by parking. The nineth bullet point has been expanded to require all new development to provide an integrated network of multi-functional public open space and green and blue infrastructure that connects with existing green infrastructure where possible. There is no definition of the term blue infrastructure anywhere in the Plan. Furthermore, this requirement may not be appropriate or necessary for all development and as such is an unjustified requirement. As currently drafted the policy is unjustified, inconsistent with national policy and prejudicial to the effectiveness of the plan.

The previous objection to the use of the word 'must' in the first paragraph of this policy is maintained as it is retained in this latest draft. As commented previously, it is important that the wording of this policy takes into account that a developer is rarely the provider of infrastructure. A good example is healthcare provision. A developer can reasonably be required to contribute towards healthcare (in the absence of CIL) but cannot be responsible for delivering the healthcare facility. The delivery of the facility relies on the actions of NHS England not the developer. As currently worded the policy is not consistent with national policy.

It is noted that the table continues to leave the annual requirement as a fixed figure rather than a minimum target which would be consistent with the stated minimum supply across the plan period. The previous request to refer to the annual supply as a minimum target is therefore repeated. It is also noted that the Plan has not been altered to explain how the need arising from London has been addressed. The previous request to address this is also repeated. It is considered that these issues raise doubts about the extent to which the plan is positively prepared and will be effective.

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7261

Received: 14/09/2017

Respondent: Tollgate Partnership Limited

Agent: Barton Willmore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

There is an oversupply of employment land when assessed against the robust scenarios in the Council's evidence base and also against the findings of the Stane Park appeal decision. The requirement is likely to be in the region of 16ha to 29.8ha. The allocation of 44.2ha of employment land is not justified. The Plan should therefore be amended accordingly to remove land not required to meet employment needs. We comment separately in relation to land forming part of the Tollgate Village retail / leisure scheme in relation to the West Colchester Policies.

Full text:

see attached

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7354

Received: 03/08/2017

Respondent: Colchester Civic Society

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Attracting New Businesses- (SG3) - we would like to see more information about how this will be achieved.

Full text:

The Colchester Civic Society has reviewed the 2017 draft plan and appreciates the work and effort that has gone into the preparation. We made some comments on the original and were interested to look at the new draft in conjunction with our previous comments. Overall, we welcome the revised draft report in principle and only wish to make a general response.
As our constitution is concerned with the town of Colchester itself, we have not commented on the urban village proposals, but we have concerns and remain sceptical.
We are not entirely convinced that all of concerns have been addressed, for example, the following issues;
Infrastructure and Schools (SG7) - will there be sufficient quality schools, major roads to support the growing population;
Air Pollution- (ENV5) This remains a concern. We would not expect a full answer, but there are parts of the town- notably Brook Street- that still have major problems;
Parking provision- (DM22) we were concerned last year that there insufficient parking provision, both for the commercial centre and generally. The loss of town centre car parks eg Britannia and Vineyard Street, will exacerbate the problem. Additional Park and Ride schemes would probably not be a full answer and is not guaranteed anyway.
Attracting New Businesses- (SG3) - we would like to see more information about how this will be achieved.
Middlewick- (SC2) The inclusion of the MOD proposals for housing on the Middlewick Ranges causes us most concern. We support the Council's view that instead of the 2000 units in the MOD proposal 1000 would be more realistic but we would like to know more details about the scheme, as this may be more than the development should support. The area is popular for walks and leisure and a large development would need open spaces, both for Middlewick and the Barnhall/Abbotts Road homes, already established. We would welcome the opportunity to comment on a detailed development brief.
Apart from this area, we have not commented on individual locations as we did in 2016 and our views have not changed.
Yours Faithfully
Peter Evans OBO Colchester Civic Society.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7470

Received: 27/09/2017

Respondent: Maldon District Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities. The expected delivery of over 126,000 sqm of B1 office space is ambitious. It is unclear as to whether there is sufficient market demand. It is not clear in the draft Plan, whether there has been any analysis of employment land requirements against housing provision. It is not clear how the allocation of existing mixed-use employment areas (eg Hythe Quay, Magdalen Street and Hawkins Road, policies EC2, EC3,) for housing has been taken into account in the calculation for employment land.

Full text:

Maldon District Council Comments

Section 1
Transport
The sections on improved road infrastructure and strategic highway connections and improved junctions on the A12 and other main roads are supported.

However, the A12 junction improvements at Marks Tey must be designed and built to accommodate the total proposed 24,000 homes in the Garden Community not just that planned for this plan period.

Due to the expected increase in leisure & recreation pressure on adjoining Districts (in particular the Dedham Vale AONB and the River Blackwater), arising from the strategic growth and Garden Communities planned in North Essex, S106/CIL contributions from these developments should include contributions towards cycle and footpath routes to enable non-car access to leisure and recreation destinations in adjoining districts.

Education
School pupils are shared across district boundaries. S106 agreements must take into account the impact on schools in Maldon District. Funding should be directed to the schools affected by the strategic growth in North Essex, even if the schools concerned are in adjacent districts.
[Effective]

Paragraph seems to have a repeated sentence/ or missing text. This paragraph needs to be revised.
[Effective]

Recreational Avoidance and Mitigation Strategies (RAMS) must cover the relevant designated sites in adjoining districts, as the recreation & leisure impacts of the strategic growth and Garden Communities will extend beyond the Borough's borders.

The supporting text needs to be revised to acknowledge that recreational and leisure impacts will be cross-boundary, and that the RAMS should also be cross-boundary, not solely focused on designated sites within the three council areas.

The impact of the Marks Tey Garden Community, in particular, on the Blackwater Estuary must be included within the scope of the Strategy.

Maldon District Council would wish to be involved in the development of the RAMS for the Braintree and Colchester Local Plans and Garden Communities.
[Effective]

The employment allocations for the Garden Communities should be explicitly stated in policy SP7 alongside the housing allocations. Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities.
[Effective]

Garden Communities - the policies map only shows 'strategic areas for development'. As the planning of the Garden Communities has been delegated down to a Strategic Growth DPD, the strategic areas as shown on the policies maps can be indicative only. It is insufficient to allocate 7,500 homes to these Garden Communities in this plan period, based on an indicative area. To provide more certainty, these areas should be defined more clearly on the Local Plan policies maps.

The employment allocation for the Garden Community should be explicitly stated in this policy alongside the housing allocations. Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities.
[Effective]

Garden Communities - the policies map only shows 'strategic areas for development'. As the planning of the Garden Communities has been delegated down to a Strategic Growth DPD, the strategic areas as shown on the policies maps can be indicative only. It is insufficient to allocate 7,500 homes to these Garden Communities in this plan period, based on an indicative area alone. To provide more certainty, these areas should be defined more clearly on the Local Plan policies maps.

The employment allocation for the Garden Community should be explicitly stated in this policy alongside the housing allocations. Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities.

The impact of a 24,000 home development at Marks Tey, on leisure and recreational facilities and infrastructure in adjoining districts needs to be calculated and planned for. For example, contributions to cycle and footpath routes to the coast and other recreational facilities should be sought, to enable non-car access to recreational and leisure destinations.

The roads infrastructure, including any A12 junction improvements must be designed to accommodate the traffic from the full 24,000 home Marks Tey Garden Community, not just the first phase of development as identified in this Plan.
[Effective]

Garden Communities - the policies map only shows 'strategic areas for development'. As the planning of the Garden Communities has been delegated down to a Strategic Growth DPD, the strategic areas as shown on the policies maps can be indicative only. It is insufficient to allocate 7,500 homes to these Garden Communities in this plan period, based on an indicative area. To provide more certainty, these areas should be defined more clearly on the Local Plan policies maps.

The employment allocation for the Garden Community should be explicitly stated in this policy alongside the housing allocations. Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities.
[Effective]

Section 2 Colchester Borough Policies
Only 4.5 ha of employment land is expected to come forward within Colchester Borough in the Garden Communities, which are intended to deliver 2,600 homes in Colchester's Housing Trajectory in this plan period. Without sufficient employment land being allocated and developed, the Garden Communities will become commuter settlements, not functional, sustainable communities.

The expected delivery of over 126,000 sqm of B1 office space is ambitious. It is unclear as to whether there is sufficient market demand for this level of allocation outside of Greater London. The ELNA Executive Summary (14th bullet) states that :
'In light of the quantitative surplus of office land to meet future business needs over the plan period, there would appear to be limited scope for identifying/allocating new land for office development over the next few years in Colchester based on current levels of business demand and rental values/viability, particularly outside of key employment areas such as Colchester Business Park and town centre'

It is not clear in the draft Plan, whether there has been any analysis of employment land requirements against housing provision. The approach to employment provision within the Garden Communities, suggests not.

It is not clear how the allocation of existing mixed-use employment areas (eg Hythe Quay, Magdalen Street and Hawkins Road, policies EC2, EC3,) for housing has been taken into account in the calculation for employment land.
[Effective]

Tiptree expansion - The Neighbourhood Plan allocation for 600 homes is in addition to the existing commitments for 400 homes in the village.

The B1022 through Tiptree is a through route to/from Colchester and Maldon District, and provides a vital alternative route when the A12 is closed. The B1023 (Inworth Road) provides access to/from the A12 via Feering and Kelvedon for the north of Maldon District. To the south of Tiptree, Braxted Park Road gives access to/from the A12 at Rivenhall End, via the grade II listed Appleford Bridge. This provides a direct route to/from the A12, however the bridge creates a major pinch point along this route. Off Braxted Park Road, Maldon Road provides access to/from Kelvedon and from there, the A12, via a narrow, single-track Grade II listed bridge. The proposed 600 new dwellings in the village, to be brought forward in the Neighbourhood Plan, along with the existing commitments for 400 homes, must not compromise these transport routes. Improvements should be made to these feeder routes to/from the A12, to ensure that the additional traffic generated by the planned 1,000 home expansion of Tiptree does not detrimentally impact these important routes.

Increased traffic movements on Braxted Park Road to/from Rivenhall and Maldon Road to/from Kelvedon, as a result of the expansion of Tiptree, must not cause harm to either of the listed bridges over the River Blackwater (Appleford Bridge on Braxted Park Road and the bridge on Maldon Road at the junction with Ewell Hall Chase).

Further, the policy states that:
'in cases where a Neighbourhood Plan fails at any time prior to being made, responsibility for all planning policy matters within that plan area will revert back to the Local Planning Authority.'
For the villages where the Neighbourhood Plan will be bringing forward significant levels of development, should this statement have a set date, to ensure that the proposed development comes forward in the expected timeframe? The Plan should be clear on how the LPA will bring forward this development in the event of a Neighbourhood Plan failure, whether through a DPD or a review of the Local Plan, including whether the proposed allocation will be redistributed if the NP allocations prove unachievable.
[Effective]

The housing trajectory and the housing provision table on pg 72 of the draft Local Plan are not as transparent or as clearly explained as they could be, and give rise to uncertainty over the delivery of housing in the plan. This could result in additional land being allocated elsewhere in the Borough that could have an impact on Maldon District.

It is not possible to reconcile the data in the table on pg 72 with the published housing trajectory.

The housing trajectory 'existing commitments' includes 802 units coming from 'applications pending.' This term needs explanation. If this means that the applications are pending consideration, then including these sites in the housing trajectory would appear to prejudice the lawful decision making process on these applications. Alternatively, if 'application pending' means that no planning application has been received, but is expected, then the site should be allocated in the plan, rather than be included within the existing commitments, and again would suggest that the applications have been predetermined. Either scenario increases the uncertainty regarding the delivery of these sites. Without these 802 units, the housing provision in the table on pg72 falls to 14,261 units, which is below the OAN of 14,720 units.

The 'existing commitments' figure includes existing allocations from the 2010 Site Allocations DPD. The majority of these are existing mixed-use employment areas (eg Hythe Quay, Magdalen Street and Hawkins Road, policies EC2, EC3). Many of these sites are not expected to deliver housing until 2027/28, meaning that they will have been allocated for over 17 years by the time they are redeveloped. It is particularly noticeable that the housing trajectory predicts that the Garden Communities will start to deliver housing before all but one of the existing allocations. This approach of allocating sites that are unavailable in the long term is questionable. This uncertainty puts further pressure on the housing delivery target, as these allocations have a capacity of 1,314 dwellings. If these sites do not come forward, the Local Plan will not be able to meet its OAN.

The housing provision table pg 72 does not include a rural exceptions site for 15 units at Layer de la Haye. As a result, the table does not add up. The table should have a footnote to this effect.

The 5YHLS supply does not include a slippage/non-implementation rate. There is no evidence in the 5YHLS or the AMR 2016 on historic expiry rates for planning permissions in the Borough. The implication is that no planning permissions in Colchester Borough ever expire.
[Justified/Effective]

The draft Local Plan does not include a review mechanism or trigger for a whole or partial review of the Plan. As a significant portion of the housing development in this plan is reliant on a number of large sites, if these sites do not come forward as expected, the delivery of the Plan could be impacted. Therefore, a review mechanism should be included in the Plan. For example:

If the Authority Monitoring Report demonstrates that the Garden Communities and the allocations deliver less than 75% of their projected housing completions in three consecutive years (based on the trajectory set out in this Plan), the Council will undertake a partial review of this Plan.
[Effective]

Maldon District Council has no comments to make on the SA/SEA.

Attachments: