Policy ENV2: Coastal Areas

Showing comments and forms 1 to 12 of 12

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6169

Received: 08/08/2017

Respondent: The University of Essex

Agent: The JTS Partnership LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The University of Essex supports the objectives underlying Policy ENV2, but objects to the extension of the Coastal Protection Belt, to include land on the east side of the river; which is allocated, in the current Local Plan, for an extension of the University Campus. This land is needed in order to meet the medium and long term strategic growth needs of the University and thus deliver the related economic and education objectives of the Publication Draft Local Plan.

Full text:

The University of Essex supports the objectives underlying Policy ENV2, but objects to the extension of the Coastal Protection Belt, to include land on the east side of the river; which is allocated, in the current Local Plan, for an extension of the University Campus. This land is needed in order to meet the medium and long term strategic growth needs of the University and thus deliver the related economic and education objectives of the Publication Draft Local Plan.

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6243

Received: 31/07/2017

Respondent: Marine Management Organisation

Representation:

No objection. I'm content and agree with the way the marine plan and MPS is cited in Env 2 and it's current layout. I'm content and agree with the text in 13:20.

Full text:

No objection. I'm content and agree with the way the marine plan and MPS is cited in Env 2 and it's current layout. I'm content and agree with the text in 13:20.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6348

Received: 06/08/2017

Respondent: Wivenhoe Society

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

The deletion from the Coastal Protection Belt of the land lying to the east and south of the Wivenhoe settlement area is based on a criterion that does not take account of the coastal, rural nature of the land concerned which is also in close proximity to a Special Protection Area and is contiguous with land which Tendring District is proposing to include in its CPB. It should continue to be part of the Colchester CPB.

Full text:

The wording of the Policy is fine but the Wivenhoe Society wished to object to the deletion of one area of the current coastal protection belt, Bowes Farm, the land lying to the east of the settlement area shown in the attachment, on the grounds that the criteria used by the consultants do not reflect the aims as set out in the supporting text for the Policy.

In the text it states
13.10 The Coastal Protection Belt protects the open and undeveloped stretches of coastline in the Borough which could be harmed by development that might otherwise be acceptable in a countryside area.
13.8 The Colchester Coastal Protection Belt aims to protect the rural and undeveloped coastline in the Borough from inappropriate development that would adversely affect its rural, undeveloped and open character and irreplaceable assets, landward and marine sites of nature conservation importance.

A review of the Coastal Protection belt was conducted by Chris Blandford Associates. This was not made available to the public for comment until late 2016/early 2017 after the Preferred Options consultation had been closed. The Wivenhoe Society commented
"Coastal Areas Policy, paragraph 5.14 : Reference is made to an updating of the Coastal Protection Belt made in 2016. No map is provided for the proposed protected area and the review does not appear in the Borough evidence base documents. In the Neighbourhood Plan survey it was clear that residents valued the open countryside and the views down the estuary from the land to the east of the Wivenhoe settlement area and to the south of Alresford Road as well as the green slopes to the west of the settlement. The land to the east is also close to a Special Protection Area and an SSSI. We would urge that this area should continue to form part of the Coastal Protection Belt."

The consultants used different criteria from those used by Essex County Council in 1984 when the current Coastal Protection Belt was defined. These earlier criteria included coastal views. The consultants instead used landscape character areas. The site in question was classified by the consultants as partly falling in a category "Colne Slopes" (land much further upstream was also designated as Colne Slopes) and partly as falling in the "Wivenhoe Plateau". Where the plateau ends and the slope starts is somewhat arbitrary as the land in question continues to rise at a decreasing rate up to the Alresford Road, the boundary of the current CPB. Most of the Wivenhoe plateau neither has coastal/estuary views nor is visible from the river and the Wivenhoe Society has no issue with accepting the proposed deletion from the CPB of land to the north west of the settlement area, which also forms part of the Wivenhoe Plateau. The land sloping down to the estuary however would seem to satisfy the criteria set out in 13.8 of the Plan text. It is coastal, rural, undeveloped and open in character. It is worth noting that Tendring District is proposing to include the Colne slopes abutting this land in its Coastal Protection Belt.

The area proposed for deletion is also very close to the Colne Mid Essex SPA. It is likely that The Essex and South Suffolk Shoreline Management Plan (October 2010) has proposals to flood the grazing meadows just to the south (ref D6b Wivenhoe Marshes) post 2025 to create wetland. This would only be separated from Bowes Farm by the railway line. The new wetland will no doubt be colonised by species of river birds that the existing SPA seeks to protect. The Bowes farm land is likely to provide feeding grounds for these birds and would also provide a roosting site in the event of very high tides. The site therefore also therefore has the potential to be important for nature conservation.

Comment on paragraph 13.19: This states "There are also a number of new housing allocations being proposed within Abberton, Rowhedge, West Mersea and Wivenhoe which are located within the revised Colchester Coastal Protection Belt". None of the new housing allocations proposed for Wivenhoe, both in this Published Plan and in the draft Wivenhoe Neighbourhood Plan are in the proposed revised Colchester Coastal Protection Belt. One site is within the current Coastal Protection Belt but the area concerned has no inter-visibility with the estuary and it is probably appropriate that this area of land should be excluded from any revised Coastal Protection Belt. Similarly the allocation at Rowhedge would not seem to lie within the proposed protection belt.

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6717

Received: 10/08/2017

Respondent: Wivenhoe Town Council

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

No map is provided for the proposed protected area and the review does not appear in the Borough evidence base documents. In the Neighbourhood Plan survey it was clear that residents valued the open countryside and the views down the estuary from the land to the east of the Wivenhoe settlement area and to the south of Alresford Road as well as the green slopes to the west of the settlement. The land to the east is also close to a Special Protection Area and an SSSI.

Full text:

Policy ENV2:Coastal Areas
The wording of the Policy is fine but the Wivenhoe Society wished to object to the deletion of one area of the current coastal protection belt, Bowes Farm, the land lying to the east of the settlement area shown in the attachment, on the grounds that the criteria used by the consultants do not reflect the aims as set out in the supporting text for the Policy.
In the text it states
13.10 The Coastal Protection Belt protects the open and undeveloped stretches of coastline in the Borough which could be harmed by development that might otherwise be acceptable in a countryside area.
13.8 The Colchester Coastal Protection Belt aims to protect the rural and undeveloped coastline in the Borough from inappropriate development that would adversely affect its rural, undeveloped and open character and irreplaceable assets, landward and marine sites of nature conservation importance.
A review of the Coastal Protection belt was conducted by Chris Blandford Associates. This was not made available to the public for comment until late 2016/early 2017 after the Preferred Options consultation was closed. The Wivenhoe Society commented
"Coastal Areas Policy, paragraph 5.14 : Reference is made to an updating of the Coastal Protection Belt made in 2016. No map is provided for the proposed protected area and the review does not appear in the Borough evidence base documents. In the Neighbourhood Plan survey it was clear that residents valued the open countryside and the views down the estuary from the land to the east of the Wivenhoe settlement area and to the south of Alresford Road as well as the green slopes to the west of the settlement. The land to the east is also close to a Special Protection Area and an SSSI. We would urge that this area should continue to form part of the Coastal Protection Belt."
The consultants used different criteria from those used by Essex County Council in 1984 when the current Coastal Protection Belt was defined. These earlier criteria included coastal views. The consultants instead used landscape character areas. The site in question was classified by the consultants as partly falling in a category "Colne Slopes" (land much further upstream was also designated as Colne Slopes) and partly as falling in the "Wivenhoe Plateau". Where the plateau ends and the slope starts is somewhat arbitrary as the land in question continues to rise at a decreasing rate up to the Alresford Road, the boundary of the current CPB. Most of the Wivenhoe plateau neither has coastal/estuary views nor is visible from the river and the Wivenhoe Society has no issue with accepting the proposed deletion to the north west of the settlement area which also forms part of the Wivenhoe Plateau. The land sloping down to the estuary however would seem to satisfy the criteria set out in 13.8 of the Plan text. It is coastal, rural, undeveloped and open in character. It is worth noting that Tendring District is proposing to include the Colne slopes abutting this land in its Coastal Protection Belt.
The area proposed for deletion is also very close to the Colne Mid Essex SPA. It is likely that The Essex and South Suffolk Shoreline Management Plan (October 2010) has proposals to flood the grazing meadows just to the south (ref D6b Wivenhoe Marshes) post 2025 to create wetland. This would only be separated from Bowes Farm by the railway line. The new wetland will no doubt be colonised by species of river birds that the existing SPA seeks to protect. The Bowes farm land is likely to provide feeding grounds for these birds and would also provide a roosting site in the event of very high tides. The site therefore also therefore has the potential to be important for nature conservation.
Comment on paragraph 13.19: This states "There are also a number of new housing allocations being proposed within Abberton, Rowhedge, West Mersea and Wivenhoe which are located within the revised Colchester Coastal Protection Belt". None of the new housing allocations proposed for Wivenhoe, both in this Published Plan and in the draft Wivenhoe Neighbourhood Plan are in the proposed revised Colchester Coastal Protection Belt. One site is within the current Coastal Protection Belt but the area concerned has no inter-visibility with the estuary and it is probably appropriate that this area of land should be excluded from any revised Coastal Protection Belt. Similarly the allocation at Rowhedge would not seem to lie within the proposed protection belt.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6731

Received: 11/08/2017

Respondent: Mrs Veronique Eckstein

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

Coastal Development Env2. referred back to from SS12b:

Significant changing in the wording of SS12b is cause for concern and lacks clarity.

There is a watering down of protection of internationally designated sites and this may not be consistent with the Council's obligations to protect these areas.

The current adopted plan DP23 gives better protection to undeveloped areas of foreshore and does not need much change.

Full text:

Coastal Development Env2. referred back to from SS12b:

Significant changing in the wording of SS12b is cause for concern and lacks clarity.

There is a watering down of protection of internationally designated sites and this may not be consistent with the Council's obligations to protect these areas.

The current adopted plan DP23 gives better protection to undeveloped areas of foreshore and does not need much change.

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6878

Received: 20/08/2017

Respondent: Natural England

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation:

Officer summary - Caution should be used around term irreplaceable in relation to natural assets - doesn't align with aspirations of Shoreline Mangement Plan which aims to replace lost saltmarsh which cannot therefore be regarded as irreplaceable. Policy could be strengthened by the inclusion of seascape as well as landscape character of the coast.

Full text:

Para 13.15 (previously Para 5.12) - We reiterate caution around using the term "irreplaceable" in relation to natural assets (i.e. coastal habitats). This may imply that inter-tidal habitats (especially saltmarsh) cannot be replaced, and this does not align with the aspirations of the Shoreline Management Plan (one major aim of which is to replace lost saltmarsh, which cannot therefore be regarded as "irreplaceable"). We suggest that a different term is used to express the importance of coastal habitats.

As we previously advised, the policy could be strengthened by the inclusion of seascape as well as landscape character of the coast.

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6898

Received: 21/08/2017

Respondent: Environment Agency

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Support the thrust of the policy, but suggest that plan should identify a Coastal Change Management Area (CCMA) for any area likely to be affect by physical changes to the coast to make clear as to what development will be appropriate in such areas. A CCMA should be identified for Mersea Island.

Full text:

We support the thrust of this policy and welcome item (ii) which we note states development will only be supported where it can be demonstrated that, among other things, it is on a land use type that is appropriate to the Flood Zone.

We support paragraph 13.17 in particular the reference to future land uses demonstrating a high level of resilience in response to changing local climatic conditions.

Our letter dated 8 September 2016 put forward the case for applying a coastal change management area at Mersea Island - this being based on Paragraph 071 of the National Planning Practice Guidance (7-071-20140306) which suggests that a Coastal Change Management Area (CCMA) should be identified by a Local Plan. This is described as an area which is likely to be affected by physical change to the shoreline through erosion, coastal landslip, permanent inundation or coastal accretion.

Furthermore, paragraph 072 (ID 7-072-201403060) states 'A Coastal Change Management Area will only be defined where rates of shoreline change are significant over the next 100 years, taking account of climate change. They will not need to be defined where the accepted shoreline management plan policy is to hold or advance the line (maintain existing defences or build new defences) for the whole period covered by the plan, subject to evidence of how this may be secured.'

Paragraph 106 in the National Planning Policy Framework (NPPF) advises local planning authorities (LPAs) should identify as a CCMA any area likely to be affected by physical changes to the coast. In doing LPAs should be clear as to what development will be appropriate in such areas and in what circumstances and make provision for development and infrastructure that needs to be relocated away from CCMAs.

Section 4.6 of the Essex and South Suffolk Shoreline Management Plan provides a plan summary for Management Unit E (Mersea Island). The variance in policy can be seen on policy maps 4-17 to 4-20 and includes areas of 'managed realignment' and 'no active intervention'. It does not appear that defining a CCMA for Mersea Island has been addressed by the Council. We consider that defining a CCMA will enable, as based on paragraph 106 in the NPPF, a more structured approach to the consideration of development proposals based on physical constraints and the policy position in section
4.6 in the Essex and South Suffolk Shoreline Management Plan.

In the light of paragraph 106 of the NPPF and the thrust of Management Unit E in the Essex and South Suffolk Shoreline Management Plan, we consider that, as matters stand, the Local Plan is not fully consistent with national policy. Given this situation, the Local Plan is unsound in relation to the absence of a CMMA for Mersea Island. This situation can be overcome through the identification of Mersea Island as a CCMA.

Attachments:

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 6957

Received: 24/08/2017

Respondent: Historic England -East of England

Representation:

HE welcome the reference to "heritage assets" in Policy ENV2 and the change to the wording in paragraph 13.16.

Full text:

We welcome the reference to "heritage assets" in Policy ENV2 and the change to the wording in paragraph 13.16.

Attachments:

Support

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7112

Received: 05/09/2017

Respondent: Colchester Natural History Society

Representation:

This Coastal Areas policy is welcomed.

Full text:

COLCHESTER NATURAL HISTORY SOCIETY (CNHS)
RESPONSE TO COLCHESTER BOROUGH COUNCIL (CBC)
PUBLICATION DRAFT LOCAL PLAN (LP) 2017 - 2033
CNHS Ref. LP
Ref. COMMENTS
North Essex Authorities Strategic Section 1 for Local Plans
1 Policy SP8 Tendring/Colchester Borders Garden Community.
CNHS welcomes the statement "Safeguarding the important green edge to Colchester will be essential with a new country park along the Salary Brook corridor and incorporating Churn Wood" and would wish this to be strengthened to reference the vital biodiversity of the area. It would be preferable that the country park area be a designated Local Nature Reserve.
Colchester Borough Local Plan 2017 - 2033
2 Policy ENV1 This environment policy is welcomed for its intentions to protect key sites. CNHS strongly feels this should also apply to Local Nature Reserves to ensure that there is no reduction in or threat to these key sites within the Borough.
3 Policy ENV2 This Coastal Areas policy is welcomed.
4 Policy ENV3 This Green Infrastructure policy is welcomed to safeguard and enhance green corridors and connectivity and to provide green protection belts around key sites.
5 Policy SC1 Any proposed development in the Gosbeck area should, in addition to the sensitivity of the archaeology, also pay careful regard to the areas biodiversity.
6 Policy SC2 CNHS notes the policy plan to review the Middlewick ecology and provide compensatory habitat where required. It will be essential that key areas are protected by affective buffer zones and that where necessary green linkage corridors are provided.
7 Policy WC2 This policy references development land at Chitts Hill. In doing so at point (iv) it recognises the close proximity of the Local Wildlife site Iron Latch Woods and Meadows. CNHS welcomes the intention to provide open space and green infrastructure to compliment this important biodiversity site and urges that the sites integrity is in no way undermined by any development.
8 Policy WC3 CNHS urges that any development of Colchester Zoo should not pose a threat to the integrity of the biodiversity importance of the Roman River Valley.
9 Policy WC4 The proposed development land at Irvine Road is an orchard. Orchards provide unique habitat for wildlife and whilst CNHS acknowledges that it is proposed that 60% of the site will be subject to ecological improvement plans CNHS would prefer that the whole site be retained as a wildlife orchard and expert advice sought on how best the site could be enhanced both as an orchard and an important urban biodiversity site. CNHS would welcome the opportunity to see the ecological report and to be involved in any consultation process regarding the orchard's future.
10 Policy SP8 This policy on the proposed east garden community should have embedded within it recognition of the vital biodiversity value of the Salary Brook area and to record the firm proposals to afford the site a protective buffer zone in the form of a new country park or preferably an extended Local Nature Reserve. There is no reference to this which is a serious omission and should be rectified prior to this LP being offered for independent examination. See also CNHS Ref. 1 above.


Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7170

Received: 07/09/2017

Respondent: Gladman Development

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Gladman are concerned that the policy as written could have a significant impact on the delivery of sustainable development in coastal areas.... the first criteria as written defines that development will only be supported where it can demonstrate a coastal location is required.

Full text:

see attached statement

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7334

Received: 19/09/2017

Respondent: Messers . Hutley, Molyneux & Went

Agent: Boyer

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Precautionary approach to coastal areas understood, however there is some potential for development adjoining the built up areas of the coast while still protecting unique character. Wording for amended policy provided to reflect this point.

Full text:

Policy ENV2: Coastal Areas
It is noted that the policy takes a precautionary approach to restrict development to within the built up areas of the coast. We understand the need for protecting the character of the Coastal Protection Belt (CPB), however we do consider there is some potential for development adjoining the built up areas of the coast, whilst still protecting the unique character. This also reflects the approach taken elsewhere in the Local Plan which suggests potential allocations in West Mersea within the CPB. As such we request that the policy is amended as follows:
'(i) Requires a coastal location and is located within or adjoining the developed area of the coast;...'
Our client's land is located in West Mersea and this is discussed further below. However development of the site would provide a housing development that could meet the remaining requirements of Policy ENV2 including:
 it would be safe from flooding and coastal change;
 it would not be significantly detrimental to conserving important nature conservation, historic environment assets, maritime uses and the landscape character of the coast;
 it would deliver social and economic sustainability benefits through the provision of housing;
 opportunities for adaption to climate change would be considered as part of any proposals; and
 it would not hinder the potential future creation and maintenance of a continuous signed and managed coastal access route.

Attachments:

Object

Section 2 - Publication Draft Colchester Borough Local Plan

Representation ID: 7448

Received: 21/09/2017

Respondent: STOP350

Number of people: 1163

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

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 Medical care on the Island. It is the submission of the Group that the DLP is unsound in respect of its proposals for 200 dwellings in West Mersea and Caravan Parks on Mersea Island.

Full text:

* 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.

Attachments: