Friday 9 September 2016

Colchester Council Draft Local Plan Consultation 2016

Colchester Council are currently running a consultation on their 'Colchester Borough Council Local Plan Preferred Options 2017-2032'.

The proposed enormous development to the East of Colchester / West of Tendring is covered.

The deadline for submissions is: 5pm on Friday 16th September 2016.

This consultation is in addition to the one run by Tendring Council, which I emailed about previously.

The Colchester consultation is described here:

Colchester Council - Emerging Local Plan 2017-2032

A proposed response is below, which has been prepared together with greenstead.online.

Colchester Council prefer to receive comments online, which means you will need to register as described on the web page linked-to above.

You can also send comments by email or post, though, as described here:

http://www.colchester.gov.uk/CHttpHandler.ashx?id=21970&p=0#page=14

Please use your own words if possible, using what we have written as a guide if you agree.

If you use the template below, please feel free to amend the text to fit your views, and add other views if you read the document from the web page linked above. You might want to highlight any parts of your answers different from ours, to be sure the council take note of them.

Anonymous responses will not be accepted, so you must include your full name and address. The council may publicly publish responses, but I assume contact details will not be included - please check the web page above, or contact Colchester Council if you are worried about this.

Please send the following online (after registering as described above). If you send your comments by email or post, please also include the relevant parts relating to addresses below.

If you submit online, add the comments below on policy SP8. You may need to split the main comment into multiple parts if you reach a  word limit on the website. In that case, submit it on different sections of the form, but please make clear that all of these split parts of the submission refer to Policy SP8.

(A direct link to Policy SP8, which you can use after you have logged-in, is here:
https://colchester.jdi-consult.net/localplan/readdoc.php?docid=3&chapter=2&docelemid=d49#d49
Click the green pencil symbol to enter your response.)

If you submit online, a summary will be requested. A suggested text for the summary is:
"Any new development to the East of Colchester should be over the brow of the hill and out-of-sight of existing residents of Greenstead and Longridge Park, creating a buffer zone of at least 1.5km to match the one shown on the East of the new development. Infrastructure, flood risk and affordable housing should also be considered. Details in my representation."
For the Infrastructure submissions below, please submit them on the relevant parts of the document online, if possible - otherwise, enter them under Policy SP8 along with the others.

[Start of email or letter - for online submissions only include the comments, not the address details. The comments may need to be split as described above when submitting online.]
Email subject: Colchester Borough Council Draft Local Plan Preferred Options Consultation 2016
To: Planning Policy,
Colchester Borough Council,
Rowan House,
33 Sheepen Road,
Colchester,
CO3 3WG
Email: local.plan@colchester.gov.uk
From: [Your name here]
[Your Full Address Here]
Email: [Your email address here]
Telephone: [Your telephone number here - this may not be necessary]
Dear Sir/Madam,
Here are my comments on the Colchester Borough Council Draft Local Plan Preferred Options Document 2016.
Please personally send me confirmation of receipt of this email and display my comments, without my personal details, on your web site.
Policy SP8 - East Colchester / West Tendring New Garden Community
Here are my comments:
(Note to Colchester Council: The following text has been significantly updated on 9 September 2016, since previous text sent to Tendring Council.)
Regarding point 'v' - 'A high proportion of the garden community will comprise green infrastructure including a new country park around Salary Brook':
In Section 2.1 of the document ‘North Essex Garden Communities Concept Feasibility Study, Volume 2: Opportunities and Constraints’, the council state “Importantly, sufficient distance should be maintained between the Garden Community and the village of Elmstead Market to protect against settlement coalescence”.
With regards to the community of Greenstead, the same document states “it may be appropriate to create pedestrian connectivity between Greenstead and the Garden Community”, and describes “the potential to integrate with existing residential development”. Again, Section 3.3 of the document ‘North Essex Garden Communities Concept Feasibility Study, Volume 3: Options and Evaluation’ proposes on the one hand that “Elmstead Market is protected by a green buffer beyond the eastern site boundary”, yet when it comes to Greenstead and the new garden community “some form of pedestrian/cycle connectivity” is proposed to “assist with integration of existing and new development”.
It is unclear as to why the residents of Greenstead and Longridge Park are expected to ‘integrate’ with the new development in the interests of ‘cohesive communities’, while Elmstead Market is given a ‘key buffer zone’ to protect against ‘settlement coalescence’; why ‘integration of existing and new development’ is expected of the residents of Colchester, whereas ‘sufficient distance’ and a ‘green buffer zone’ are considered essential for Elmstead Market? Are the residents of Colchester less important than those of Elmstead Market? In the interests of fairness, an equally wide ‘buffer zone’ should be implemented on both sides of the new development, to prevent urban sprawl.
Therefore, in the interests of the Colchester and particularly Greenstead, the country park around Salary Brook should form a ‘buffer zone’ between existing residents of Colchester and any new development.
In particular, any new development should be over the brow of the hill heading away from Salary Brook, and thus out of sight of existing residents of Greenstead and Longridge Park in Colchester.
The Strategic Green Gaps Policy is relevant here, and should be applied.
The East side of Colchester is already well-developed, but has some well-used and important green open spaces nearby which are valued by the public, and are important for wildlife. These green open spaces, stretching to a distance of at least 1.5km away from existing development, should be untouched by new development, as described later in this answer. Too much new development directly on the Eastern border of existing developed areas of Colchester would destroy the semi-rural character of the current area, and create an unpleasant and unmanageable urban sprawl.
Furthermore, Tendring Council, by introducing a significant amount of residential or other development into the countryside to the East of Colchester, would materially harm the character and appearance of the rural area contrary to the objectives of national policy (National Planning Policy Framework, 2012, paragraph 17, 5th bullet point; paragraph 109; and paragraph 81 is also related, although paragraph 81 is specific to Green Belts). This may also contravene local planning policy.
Local and national policy should collectively recognise the intrinsic character and beauty of the countryside, seek to enhance the rural landscape and visual amenity of any Green Belt or general green land, and prevent development conspicuous from within any Green Belt or general green land which would have an excessive impact on rural character.
If there is to be new development to the East of Colchester, there should be a buffer (or country park) of green, completely undeveloped land of 1.5km around Salary Brook.
This protected 'Salary Brook Valley and Slopes' would include the Salary Brook itself, plus currently-undeveloped land 1.5km either side of the brook, along its entire length between Ardleigh and where the brook meets the River Colne.
One of the Colchester community groups organised an e-Petition with Colchester Council called 'Save Salary Brook Valley' which has nearly 800 signatories, available at http://colchester.cmis.uk.com/colchester/ePetitions/tabid/115/ID/1/Save-Salary-Brook-Valley.aspx. There is also a more recent e-Petition organised by greenstead.online at http://greenstead.online/petition/ which has over 600 signatures.
Please also take into account all objections to the 'Colchester Fringe' proposals received during your 6th January 2014 to 17th February 2014 public consultation and the Tendring District Local Plan: Issues and Options 2015 Consultation.
Regarding Infrastructure
- Hythe Station
The Hythe Station is an important asset for residents of Greenstead and Longridge Park in Colchester, and all its services should be maintained or increased.
- Infrastructure First
Any housing development approved to the East of Colchester must be made conditional on the planning, implementation and completion of the infrastructure required to support that development (roads, public transport, schools, healthcare, community facilities, sports and recreational facilities) before the new residential areas are opened.
Colchester Council acknowledge the importance of infrastructure in the 'Sustainability Appraisal for Part One of the Local Plan' document: "6.10.3 - Secondary Effects: The emergence of this Garden Community can be expected to have further significant secondary effects on the wider area, associated with the necessary infrastructure provision required of development at that scale." Policy SP8 states the need for “a phasing and implementation strategy which sets out how the rate of development will be linked to the provision of the necessary social and physical infrastructure to ensure that the respective phases of the development do not come forward until the necessary infrastructure has been secured.” It is vital that this is strategy is comprehensively set out before building commences so that social and physical infrastructure is in place to support the necessary development.
- Flood Risk
A full assessment must be made of the risk of any new development making the existing potential for flooding problems in the Salary Brook area any worse, and binding guarantees being obtained from water companies and the developers that specific measures that will be implemented to prevent the new development from increasing the flood risk, and to mitigate the existing level of flooding in the area.
In Section 2.11 of the document North Essex Garden Communities, Concept Feasibility Study, Volume 1: Baseline Compendium, the council state:
"Surface water networks are at capacity and potential new developments would need to deal with their surface run-off in a way that does not impose any additional load on the system. In practice, this means that surface water cannot be discharged to the existing disposal network. The use of infiltration SuDS may be restricted due to impedance from the soil structure. This could be beneficial for on-site water storage for reuse." “The site sits within both surface and groundwater nitrate vulnerability zones, in which future development will need to ensure that land use does not increase the level of nitrate in groundwater and mitigate any potential affects (sic) on groundwater supply.” and “Salary Brook is a highly modified water course with moderate ecological potential. It is at risk from further ecological deterioration."
In Section 2.3 of the document North Essex Garden Communities, Concept Feasibility Study, Volume 2: Opportunities and Constraints, the council state:
“The topography of the site coupled with reduction in impervious surfacing associated with development along with impeded drainage potential of clay soils and underlying geology will result in high run-off rates that will need to be managed.”
These are serious concerns which must be fully addressed by the water companies before any development can be approved.
[End of email, letter or online submission]

Regards
James
Colchester East Action Group (CHEAG)
Blog: http://cheag.blogspot.co.uk/

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