Colchester Publication Draft Local Plan: Consultation Document

Forward Plan reference number: FP/842/05/17

Report title: Colchester Publication Draft Local Plan: Consultation Document (Regulation 19), June 2017 Report author: Dominic Collins, Director Economic Growth and Localities Date: 12 July 2017 For: Decision Enquiries to: Matthew Jericho, Spatial Planning Manager matthew.jericho@essex.gov.uk Ph: 0333 01 30557 County Divisions affected: All Divisions within Colchester Borough Council and those divisions that adjoin Colchester Borough.

1. Purpose of Report

1.1 The purpose of this report is to provide details of Essex County Council’s (ECC) formal response to the final round of public consultation on the Colchester Borough Council (CBC) Publication Draft Local Plan (the Draft Plan).

2. Recommendations

2.1 To agree to send to CBC the response to the consultation on the Draft Plan that is contained in Appendix 1 to this report (ECC’s response) and endorse the comments in ECC’s response as the basis for ECC’s written representations to be submitted to the Planning Inspector appointed to conduct the independent Local Plan examination.

2.2. To agree to confirm that ECC will continue to work with CBC through the duty to cooperate towards the refinement of the Draft Local Plan and the supporting evidence base with the aim of supporting CBC’s Submission Plan and its subsequent Examination in Public.

3. Summary of issue

Background – Local Plan Development

3.1 CBC began preparation of a new Local Plan in 2014 and carried out an Issues and Options consultation in 2015 followed by a Preferred Options consultation in 2016, with all statutory bodies, relevant public and private organisations and the local community invited to comment. ECC provided a response to both consultations through a CMA (KD10 FP/958/01/15 and KD02 FP/530/06/16 respectively). Once adopted, the Draft Plan will replace and consolidate the CBC’s adopted Core Strategy (2010), Development Policies Plan and Site Allocations Plan (2010) as amended through Focused Changes in 2014 that sought compliance with the National Planning Policy Framework (NPPF).

3.2 Following a review of the representations received in 2016 at the Preferred Options consultation stage, including the evidence base and on-going work with statutory bodies, relevant public and private organisations (including ECC) and the local community, CBC is now consulting on a Draft Plan with consultation running from

16 June to 11 August 2017. This final stage of local plan preparation is known as the Publication stage (or informally ‘Pre-Submission’), as it is this resulting version of the Local Plan that CBC intends to submit to Government for approval through an Examination in Public.

3.3 The Draft Plan sets out how the Borough’s development and growth requirements for the period 2013 to 2033 will be met. In preparing the Draft Plan joint working has taken place between CBC, Braintree District Council (BDC) and Tendring District Council (TDC) in collaboration with ECC, to identify and address cross boundary strategic issues and priorities in accordance with the NPPF. One outcome was the alignment of Local Plan preparation and consultation timeframes between the three Local Planning Authorities (LPAs) and the preparation of a common ‘Section 1’ to the Draft Plans for BDC, CBC and TDC in order to address the strategic issues. Section 1 was first included as part of the Preferred Options document in 2016.

3.4 Section 1 of the Draft Plan contains the strategic policies applicable to the three LPAs including proposals for three Garden Communities; two of which are part located in CBC; one to the west of the Colchester urban area crossing the CBC and BDC border, and one to the east crossing the CBC and TDC border (further detail provided from paragraph 3.8 onwards). The third is located wholly within BDC on the Uttlesford District Council border. Section 2 of the Draft Plan contains the local policies and allocations specific to each LPA.

3.5 The Draft Plan is the product of an evidence-based process in line with national regulations, policy and guidance. The evidence base supports both Section 1 and Section 2 of the Draft Plan. This covers, but is not limited to, a range of topics such as housing, employment, retail, Garden Communities, transport, infrastructure (green, social and physical), environment, flooding and viability.

3.6 Following this round of public consultation, the Draft Plan and all representations on it received by CBC will be submitted to Government in October 2017 for examination alongside the Sustainability Appraisal/Strategic Environmental Assessment (SA), and supporting evidence base. There will be two ‘examinations in public’ involved in plan adoption. Section 1 will be examined jointly and first. Assuming that the Planning Inspector is able to confirm that, in principle, Section 1 is ‘sound’ then there will be a separate examination of Section 2 of the Draft Plan. The examination process and timings are to be confirmed by the Planning Inspectorate (PINS).

3.6 It should be noted that BDC and TDC are consulting on their own Publication Draft Local Plans at the same time as CBC. As with CBC, their Publication Draft Plans include the common Section 1 and the locally specific Section 2. A separate CMA outlines the recommended ECC response for each plan. The commentary and recommendation for Section 1 is the same for all three plans as it is common to all of them, whereas recommendations for amendments to policy wording and supporting text for Section 2 of each Draft Local Plan is specific to Colchester, Braintree and Tendring.

Publication Draft Plan (this consultation)

3.7 The following paragraphs summarise key elements of the Draft Plan.

Content of the Plan – Section 1:

3.8 Section 1 of the Draft Plan provides a set of common strategic objectives, policies and high level allocations to be included in the three Local Plans prepared by Colchester, Braintree and Tendring Councils (collectively referred to as ‘North Essex’). The three LPAs, in consultation with ECC, have continued to work together to address strategic planning matters across North Essex. Accordingly, Officers and Members from North Essex and ECC have worked closely during the preparation of the three Publication Draft Plans, particularly in relation to the proposals for new Garden Communities. ECC is a key partner promoting economic development and regeneration, and has a strategic role in terms of infrastructure and service provision, and as the Highway Authority, Local Education Authority, Minerals and Waste Planning Authority, Lead Local Flood Authority and lead advisors on Public Health.

3.9 Section 1 sets the strategic approach the three LPAs will take to meet the objectively assessed need for development land (the housing and employment requirements). The main purpose of Section 1 is to:

a. Articulate a spatial portrait of the combined area (Braintree, Colchester and Tendring referred to as ‘North Essex’), including its main settlements and strategic infrastructure, as a framework for accommodating future planned growth; b. Provide a strategic vision for how planned growth in North Essex will be realised; c. Set strategic objectives and policies for key growth topics; d. Set out the numbers of additional homes and jobs across the area that will be needed over the period to 2033 (the Plan Period). The choices made, particularly in relation to the location of Garden Communities, will also set the framework for development well beyond the plan period; and e. Highlight the key strategic growth locations across North Essex and the necessary new or upgraded infrastructure to support this growth.

3.10 A summary of each Section 1 policy is provided below together with an overview on where amendments have been made following the Preferred Options consultation, and where this reflects an ECC representation and on-going engagement with ECC. Those changes have been made jointly by the three LPAs and where relevant in consultation with ECC; and primarily relate to providing greater clarity and any minor modifications required to reflect updated evidence and process. It is recommended that ECC propose several minor amendments for clarity as outlined in Appendix 1.

3.11 Policy SP1 (The presumption in favour of sustainable development) has been included to comply with the NPPF and is a requirement from PINS. No changes have been made and there was no ECC representation on this policy at the Preferred Options stage.

3.12 Policy SP2 (Spatial Strategy for North Essex) outlines in broad terms how and where development will take place. The spatial strategy will focus growth on existing settlements, prioritising the re-use of previously developed land. Development will be accommodated within or adjoining settlements according to their scale, sustainability and existing role within each borough/district. Beyond these

settlements, rural diversification and the conservation and enhancement of the natural environment is supported. Three new Garden Communities are proposed and would supply a total of 7,500 new homes in the Plan Period, accompanied by employment and community uses, with significant further growth to take place in each Garden Community beyond the Plan Period (see paragraph 3.21). They will be developed on ‘garden communities principles’ (based on the Town and County Planning Association’s principles for ‘Garden Cities’), with necessary infrastructure and facilities. These new Garden Communities are proposed in Policy SP7 and specific policy requirements for each Garden Community are outlined in Policies SP8, SP9 and SP10.

3.13 Policy SP2 was previously Policy SP6 at the earlier Preferred Options (2016). It has now been moved to the beginning of Section 1 to reflect its importance. No other changes have been made to Policy SP2 and there was no ECC representation on this policy at the Preferred Options stage.

3.14 Policy SP3 (Meeting Housing Needs) and Policy SP4 (Providing for Employment and Retail) (previously policies SP2 and SP3 at the Preferred Options stage) reflect the evidence base work carried out by the three LPAs to establish Objectively Assessed Need. The table below shows the housing and employment requirements in the Plan Period. With the exception of the three Garden Communities, Section 2 of each Publication Draft Local Plan provides the detail on where employment and housing development will take place (the site allocations) and any associated planning requirements for those allocations.

Local Net Minimum net Jobs Hectares of B use Planning additional additional forecast employment land Authority dwellings homes in per per annum plan period annum Baseline Higher scenario

Braintree 716 14,320 490 23 43.3 Colchester 920 18,400 928 22 55.8 Tendring 550 11,000 490 22 38 TOTAL 2,186 43,720 1,908 65 137.1

3.15 Each LPA is able to meet their own housing requirements wholly within their administrative boundaries. The housing evidence base includes Chelmsford as it is located within the same housing market area as Braintree, Colchester and Tendring. It should be noted that Chelmsford is not part of the Section 1 as it is preparing its new Local Plan separately and to its own timetable. Chelmsford’s Preferred Options Draft Local Plan finished public consultation in May 2017 (ECC response FP/781/03/17) and referred to collaborative working with North Essex and the ability of Chelmsford to meet their own housing requirements within their administrative boundaries.

3.16 Since the Preferred Options consultation by CBC, updated demographic projections from 2014 have been released. A revised Objectively Assessed Housing Needs assessment was published for the housing market area in November 2016. The revised figures have been included in Section 1. This saw Braintree’s housing requirement reduce from 845 pa to 716 pa. Colchester remained the same at 920 pa and Tendring was confirmed at 550 pa from an initial range of 550 to 600 pa.

There was no ECC representation made in respect of Policy SP3 at the Preferred Options stage.

3.17 Policy SP4 addresses the objective of creating a sustainable balance within the three authorities between jobs and the available labour force through population growth. The policy has been amended from the Preferred Options version to now include forecast job numbers and revised B use employment land requirements reflecting an updated evidence base.

3.18 As part of the work to assess housing requirements, the three LPAs undertook an analysis of economic forecasts together with demographic projections to establish the inter-relationship between population growth, forecasts of new jobs and the number of new homes needed to accommodate these levels of growth. Employment Land Needs Assessments have been carried out by each LPA which set out the amount of employment land that is required within the Plan Period. Job forecasts have also been developed using two standard models, which forecast total job growth based on past trends (East of England Forecasting Model – for Colchester and Braintree, and Experian for Tendring). Each LPA has been advised on the most appropriate modelling figure to use in the context of reconciling job and housing demand. The evidence shows that proportionately there is a greater quantum of new floorspace per job in Braintree and Tendring than in Colchester. This is a function of the prominence of higher density office requirements in Colchester and lower density logistics and industrial uses in Braintree and Tendring.

3.19 The three LPAs and ECC commissioned work to explore the employment opportunities associated with the development of the Garden Communities based on the likely demographic profile of these new communities and to develop quantified scenarios for future employment growth. The consultants concluded that assuming political commitment and proactive delivery on the part of local authorities, Garden Communities had the potential to deliver one job per household, in line with the North Essex Garden Communities Charter, and to support employment growth in surrounding areas. The Tendring/Colchester Borders Garden Community is considered to perform the best in employment terms given the opportunities provided by its location adjacent to the University Essex, but the other two Garden Communities also are well-placed to take advantage of employment opportunities in new technology-based businesses, construction of the Garden Communities, access to employment opportunities in Colchester and Braintree town centres, meeting the growing need for local services, and accommodating elements of the logistics supply chain.

3.20 Employment forecasts for the three authorities accordingly factor in the longer-term aspirations for employment growth arising from the positive ‘spin-offs’ associated with Garden Communities. It is important to note, however, that while job numbers can be expected to grow at a consistent rate, current trends point to overall lower requirements for additional B1 floorspace. This reflects the growth of home working enabled by enhanced digital connectivity; the continuing decline of manufacturing with its need for large floor areas; and the prevalence of ‘hot desking’ leading to lower requirements for office floorspace.

3.21 At the preferred options stage ECC supported this policy. The amended policy is supported as it clarifies employment requirements. ECC will continue to work with all North Essex authorities to facilitate the delivery of economic growth.

3.22 Policy SP5 (Infrastructure and connectivity) outlines that up-front provision of infrastructure is a fundamental principle of the Draft Plan and requires that ‘development must be supported by provision of infrastructure, services and facilities that are identified to serve the needs arising from new development’. The policy lists the key transport, education, health and broadband infrastructure requirements for the strategic area, including improvements to the A12, A120, and including the potential for high quality rapid transit and local network improvements. Increased emphasis is placed on sustainable modes of travel covering public transport, walking and cycling. New development will also be required to provide for its education and health needs. Fast broadband connections and telecommunications will need to be provided by developers in all new development, at the earliest opportunity.

3.23 Policy SP5 has been amended from the Preferred Options version to provide a more succinct commentary and policy and reflect an updated position, particularly for transport issues and Garden Communities. ECC recommended several changes at the Preferred Options stage regarding the strategic planning transport context in North Essex, particularly with regards to the A12, A120 and relevant route based strategies, together with minor editorial changes. The changes have been incorporated into a revised policy. Many representations to the LPAs at the Preferred Options stage raised the uncertainty regarding the delivery of the A12 and A120. The A12 scheme to widen the road between junctions 19 and 25 is within a committed government programme to begin building by 2020. In March 2017 ECC completed an options consultation on potential routes for the A120 for that section between Braintree and the A12. ECC will recommend a preference to government in autumn 2017 and will lobby for the project to be included in the Road Investment Strategy commencing 2020. ECC will maintain close working relationships with the Department of Transport, Highways England and the LPAs to facilitate delivery of this important strategic project.

3.24 Policy SP6 (Place-shaping principles) establishes high standards for urban and architectural design to underpin all new development. It sets the context for the Garden Communities policies SP7-10 which establish their guiding principles and identifies their broad locations (see below). There was no ECC representation on this policy at the Preferred Options stage. It should be noted that ECC, in consultation with the Essex LPAs, is leading a review of the Essex Design Guide (EDG), which can assist in the delivery of Policy SG6. The revised EDG will continue to provide guidance and advice to assist LPAs in the determination of planning applications including large scale strategic development proposals as well as new information covering designing for access, health and active lifestyles; specialist housing - social care/elderly person accommodation; smart digital technology, broadband quality and capability and best practice; design guidance for rural communities; starter units, grown-on space and business incubators; Lifetime Homes and best practice; employment land; and town centres guidance.

3.25 Policies SP7, SP8, SP9 and SP10 relate to the development and delivery of new Garden Communities. Agreement on the general principles underpinning Garden

Communities will be followed by separate Strategic Growth Development Plan Documents (DPDs) (or site specific Local Plans) for each Garden Community. The DPDs will be developed jointly by the relevant authorities (involving ECC) and reported to the LPAs prior to formal consultation. The Section 1 policies provide the requirements and broad framework for their planning and development.

3.26 Policy SP7 proposes three new Garden Communities (GCs) as follows:  Tendring / Colchester Borders (to the east of Colchester urban area and west of Elmstead Market), a new Garden Community will deliver up to 2,500 homes within the Plan Period (as part of an overall total between 7,000 to 9,000 homes).  Colchester / Braintree Borders (to the west of Colchester urban area in the vicinity of Marks Tey), a new Garden Community will deliver up to 2,500 homes within the Plan Period (as part of an overall total of between 15,000 to 24,000 homes).  West of Braintree, in Braintree DC (on the boundary with Uttlesford DC), a new Garden Community will deliver up to 2,500 homes within the Plan Period (as part of an overall total of between 7,000 to 10,000 homes).

3.27 For each Garden Community broad locations rather than a ‘red line boundary’ are shown on the Policies Map accompanying the Draft Plan. This approach provides flexibility as the boundaries will be established through the Strategic Growth DPDs for each Garden Community, and subject to separate public consultation. The DPDs will address the development and delivery of these new communities including place-making and design quality; housing; employment; transportation; community infrastructure, and other requirements as outlined in Policies SP8, SP9 and SP10.

3.28 Since the Preferred Options consultation, the overall quantum of housing has increased for the Colchester Braintree Border Garden Community from an upper limit of 20,000 homes to 24,000 to provide flexibility as options for the Garden Community are further explored. The quantum for the West of Braintree Garden Community has been reduced from a range of 10,000 to 13,000 new homes to 7,000 to 10,000. There was no change to Tendring Colchester Borders Garden Community. In addition, Policy SP10 (West Braintree Garden Community) now references the allocated minerals extraction site allocation contained in the Essex Minerals Plan (2014) at Broadfield Farm. This minerals site lies in the ‘Area of Search’ for this Garden Community. Policy SP10 requires mineral extraction, and site restoration and aftercare to be planned alongside the wider Garden Community development and will be further considered through the Strategic Growth DPD.

3.29 ECC representations on policies SP7, SP8, SP9 and SP10 sought further reference and clarity on matters relating to mineral safeguarding areas, surface water management, and early years and childcare. These have been reflected in the Draft Plan. Other minor editorial changes have also been made to ensure consistency between the policies and supporting text.

Content of the Plan – Section 2:

3.30 Section 2 of the Draft Plan provides the policies and allocations for Colchester Borough only. This section includes allocations and policies organised by locality and then themes.

3.31 Vision and Objectives: The Draft Plan first outlines the local characteristics and key issues for Colchester that underpin the vision and the objectives. A number of amendments were suggested by ECC at the Preferred Options stage. References are now made in the Draft Plan to a ‘suitable housing mix’ and ‘healthy communities’ and these are supported.

3.32 Spatial Strategy: The Spatial Strategy directs development towards the most sustainable locations and provides for supporting facilities and infrastructure to create sustainable local communities. The spatial strategy for how growth and development will be managed involves: a. a continuing focus on urban Colchester; b. small scale development in identified ‘Sustainable Settlements’ (identified as other towns and villages within the Borough); and c. development of two new Garden Communities to the east and west of urban Colchester (as outlined in Section 1 of the Draft Plan).

3.33 Strategic Policies: The Draft Plan includes five strategic policies to detail the spatial strategy (Policy SG1) and to direct overall development of housing (Policy SG2), economic growth (Policy SG3), and infrastructure and developer contributions (Policy SG4). Strategic policies also include guidance and support for Neighbourhood Plans (Policy SG5).

3.34 Policy SG1 (Colchester’s Spatial Strategy) provides for a settlement hierarchy ranking areas of the Borough in order of their sustainability merits and the size, function and services provided in each area. The hierarchy focuses growth on the urban area of Colchester, with the Town Centre at its heart, reflecting its position as the main location for jobs, housing, services, and transport. Sequentially, the next tier of preferred growth includes Garden Communities covered in Section 1, which will continue to grow beyond the Plan Period. The second tier also includes proportionate growth in existing Sustainable Settlements within the Borough, including 15 large villages and the three District Centres of Tiptree, West Mersea, and Wivenhoe. In the remaining ‘Other Villages and Countryside’ areas of Colchester, CBC will limit new development to appropriate new infill developments; development on previously developed land; or extensions, restorations or alterations to existing building within the defined village limits. New development in the open countryside will only be permitted on an exceptional basis to preserve its rural character.

3.35 The Draft Plan shows that CBC will meet its Objectively Assessed Housing Need of 920 units a year over the plan period from existing commitments and new allocations. Policy SG2 provides the allocations for different geographic areas of the Borough to meet this need. Table SG2 from the Draft Plan (copied below) demonstrates that CBC has identified just over a 16 year land supply.

3.36 Colchester has an excellent track record of housing delivery. Since 1974 an average of 833 new dwellings has been delivered in the Borough every year. Over the current plan period to date (2001 – 2016) CBC exceeded its cumulative housing target by almost 900 dwellings. Therefore at the beginning of the new plan period CBC is not in a position where it needs to make up any previous shortfall in housing delivery.

3.37 The number of new dwellings for each location follows on from firstly, the broad distribution established by the Spatial Strategy (paragraph 3.30) and secondly, the analysis of capacity, deliverability, suitability and proportionality carried out by CBC through the Strategic Land Availability Assessment and the Sustainability Appraisal. CBC undertook a comprehensive review of the housing evidence base, further site assessment work (such as transport modelling) and consulted with Parish/Town Councils before finalising the Draft Plan’s housing allocations and land supply. The proposed housing supply is identified in the table below.

Settlements and Key Development Areas Existing Draft Local Plan commitments Allocations (2017-2033) Estimated minimum housing provision (2017-2033) Colchester Urban Area 5,261 2,018 Stanway 1,137 1,106 Tendring Colchester Borders Garden 0 1,250 Community Braintree Colchester Garden Community 0 1,350 Villages Aberton and Langenhoe 55 Boxted 36 Chappel and Wakes Colne 30 Copford and Copford Green 120 Eight Ash Green 150 Fordham 20 Great Horkesley 93 Great Tey 812 40 Langham 80 Layer de la Haye 50 Mars Tey 0 Rowhedge 40 Tiptree 600 West Bergholt 120 West Mersea 200 Wivenhoe 250 Extra Care Housing (self-contained) 260 Sub Total 7,210 7,868 Total 15,078

3.38 ECC comments at the Preferred Options stage sought clarity between the Section 1 and 2 housing policies. Further clarity is needed. Section 1 states 18,400 homes will be delivered 2013-2033, whereas Section 2 states 14,720 will be delivered 2017- 2033. It is recommended that Table SG2 states what has been provided to date between 2013-2016, so that it’s clear that CBC is meeting its Objectively Assessed Housing Need of 18,400 for the plan period 2013-2033. The need for a housing trajectory to support the Draft Plan was also raised at the Preferred Options stage and this has been prepared by CBC and forms part of the consultation material.

3.39 Policies SG3 and SG4 provide the policy and allocations to support economic growth in the Borough. These include allocations to address the estimated potential need for between 22 to 55.8 ha of additional B use employment land as well as scope for further alternative economic uses in other use classes to provide flexibility

in the provision of floorspace to support new jobs. The Strategic Employment Areas (the ‘best’ employment sites) include North Colchester (Northern Gateway and Severalls), Stanway, and Knowledge Gateway and University. Local Economic Areas are located within Colchester’s urban area, the main settlements and rural areas. Reference is made in the Draft Plan to Garden Communities Employment Areas where the extent, location and policy context will be the subject of further evidence, future master-planning and forthcoming DPDs for these areas.

3.40 As part of the preparation of the Draft Plan of CBC a full review of the unimplemented Strategic and Local Employment sites has been considered by CBC, taking account of the Economic Land Needs Assessment as well as settlement assessments, strategic land availability assessments and a policy review in the light of national guidance and other relevant evidence. The outcome is a list of employment land allocations in Table SG3 of the Draft Plan that provide for a total of 39.7 ha of class B use employment land in Strategic and Local Employment Areas and a further 4.5 ha of class B use employment land in Garden Communities within Colchester during the plan period. This total figure of 44.2 ha sits within the baseline and higher growth demand scenarios (22 to 55.8 ha). It is also recognised that a major contribution to jobs in the Borough comes from other economic uses which are not classified as B class uses eg. retail and leisure.

3.41 ECC comments at the Preferred Options stage welcomed the strategic and local allocations that reflected the need for economic growth to be targeted at the most accessible and sustainable locations. ECC also welcomed the flexibility within employment policies to allow sui generis uses in support of the Essex and Southend-on-Sea Replacement Waste Local Plan (now adopted). This approach has been retained in the policies and is supported.

3.42 The ECC response at the Preferred Options stage also mentioned an ECC study looking at ‘grow-on-space’. The Draft Plan explanatory text now refers to the ECC Grow on Space Feasibility Study and states that CBC will consider which interventions are the most appropriate and viable to ensure that provision of flexible local employment space (by tenure) in the plan area. This provides flexibility in how best to deliver this type of space over the plan period and will be facilitated by the employment policies. ECC supports such an approach as it does not restrict grown on space and allows provision to take place in a range of locations. ECC will work with CBC over the plan period to ensure effective delivery. This approach is welcomed.

3.43 Policy SG5 identifies the Centre Hierarchy for Colchester as it relates to retail uses/development. This is supported by Policy SG6, Town Centre Uses. ECC made no representations on these policies at the Preferred Options stage.

3.44 Policy SG7 addresses the provision of infrastructure to support new development. CBC has prepared a Draft Infrastructure Delivery Plan (IDP) to provide detail on infrastructure requirements arising from growth, phasing, delivery partners and funding. The IDP uses the range of studies and information on the topics contained in CBC’s evidence base and provides context and evidence for the constraints and infrastructure requirements contained in the Draft Plan’s allocations. ECC has assisted CBC with IDP preparation to reflect ECC infrastructure requirements as necessary both at a Borough and site specific level. Both authorities will also be

able to make use of the Greater Essex Growth and Infrastructure Framework (2016) which sets the overarching context for infrastructure and the availability of capital for infrastructure delivery. ECC will draw on the use of this evidence.

3.45 At the Preferred Options stage CBC had two policies relating to infrastructure provision and developers’ contributions. ECC recommended consolidation, inclusion of additional requirements and provided recommended wording, including a definition of ‘infrastructure’. CBC has merged the previous two policies and incorporated most of the ECC recommended wording. The approach as outlined in Policy SG7 is broadly supported, however reference should be made to the consideration by CBC of introducing a Community Infrastructure Levy (CIL), as included in the ECC response at Preferred Options stage. This would also link to other sections of the Draft Plan where references to CIL are made as a potential funding source. CBC should also satisfy itself that wording regarding small sites making proportionate contributions remains feasible given CIL Regulation 123 pooling restrictions.

3.46 Policy SG8 supports the preparation of Neighbourhood Plans. ECC made no representation on these policies at the Preferred Options stage.

3.47 Policies ENV1-5 cover environmental issues and Policy CC1 relates to climate change. Collectively the policies cover ‘environmental assets’. These policies protect and enhance the Borough’s natural environment and green infrastructure, ensuring continuing safeguarding of the countryside and Dedham Vale Area of Outstanding Natural Beauty. The section also includes a pollution and contamination policy to ensure development addresses and mitigates those issues. Policy ENV3 Green Infrastructure seeks provision of new green infrastructure including a Green Orbital surrounding the urban area of Colchester. Policy CC1 addresses climate change and the move to a low carbon future for Colchester. Policy CC1 provides that CBC will plan for new development in locations and ways that reduce greenhouse gas emissions, adopt the principles set out in the energy hierarchy and provide resilience to the impacts of a changing climate.

3.48 At the Preferred Options stage, ECC recommended several changes to the environmental assets policies to clarify intent, better reflect national policy requirements and minor editorial changes. The changes have been included in the Draft Plan and are supported.

3.49 It is recommended that further amendments are made to the explanatory text to Policy ENV1 to clarify the process of hedgerow protection. The amendment will ensure compliance and correct reference with national legislation.

3.50 Chapter 6 of the Draft Plan contains the Place Policies. This chapter sets out allocations and policies for specific parts of the Borough and explains how these align with the Plan’s overall spatial strategy and policy objectives. The format of the chapter reflects the Draft Plan’s spatial hierarchy, meaning that allocations and policies for the Town Centre and the surrounding urban area of Colchester come first, followed by allocations and policies for Garden Communities and each Sustainable Settlement (existing Rural District Centres and larger villages).

3.51 ECC comments in relation to the Place Policies at the Preferred Options stage focused on changes to better cover education, transport and surface water management issues. The changes have been included in the Draft Plan and are supported. It should also be noted that CBC has revised the format of its Place Policies to better reflect site requirements and the evidence to support its approach. Further information is now included on infrastructure requirements for individual allocations, which has included appropriate policy preparation input and review from ECC.

3.52 Policies and allocations for urban Colchester are now divided into five broad geographical areas (central, east, north, south, west). In terms of transport requirements, developments in each area will be expected to contribute to a package of sustainable measures including walking, cycling, public transport, travel planning and the promotion of sustainable travel (Policies TC4, NC4, SC3, EC4). Where it is demonstrated that proposals impact on the highway network, CBC will seek contributions towards mitigation and improvements to a specified list of strategic projects applicable to each geographical area. The policies reflect collaborative work with ECC as Highway Authority and the evidence from transport modelling completed by Ringway Jacobs, and commissioned by ECC for CBC.

3.53 Of note is a new site allocation for Middlewick Ranges (Policy SC2). The land owned by the Defence Infrastructure Organisation (DIO) provides for approximately 1,000 new homes. This was submitted to CBC by the DIO as part of the Preferred Options consultation. The Draft Plan states that the DIO proposed an allocation of 2,000 dwellings, however CBC note that while the site is sustainably located there are a number of site constraints which will restrict the final number of dwellings that can be delivered, such as its designation as a Local Wildlife Site and use as a recreational area. The policy requires a number of environmental, archaeological, transport and ecological surveys to be undertaken by the applicant to help determine final housing numbers and define the most suitable developable areas within the site allocation.

3.54 It is recommended that Policy SC2 require the provision of 3ha of land for a primary school and co-located early years and childcare facility, an additional 0.13 ha of land for a stand-alone 56 place early years and childcare facility, and the need for financial contributions, in accordance with ECC criteria. This is required to serve this development along with other proposed Local Plan growth around the Hythe and south east Colchester. Without this addition the Draft Plan fails to identify how a school could be delivered and is, thereby, unsound. It should be noted that this requirement is included in the Draft IDP but needs to be included in the Local Pan itself.

3.55 The approach to Stanway residential sites (Policy WC2) has also been revised. New residential allocations include the re-designation of the former Sainsbury’s site from employment to residential, if the retail proposal for the site does not succeed at planning appeal (currently awaiting decision from PINS). The Draft Plan proposes that the site could accommodate up to 200 homes in addition to ground floor small scale service and community uses to support the role of the District Centre. Land north of London Road is proposed for up to 630 homes along with a new primary school and co-located early years and childcare nursery places (as required to be delivered by ECC as Local Education Authority).

3.56 It is recommended that Policy WC2 is amended to remove reference to ‘existing capacity issues at the primary schools’. The measures currently listed in the policy are/will be implemented by ECC to address forecast growth and are not a result of Local Plan growth. It is not necessary to list these measures in policy. Contributions towards education should be paid by all the sites listed in Policy WC2 and not just Dyers Road. A better approach is not to list specific financial contributions against individual allocations but instead ensure that Policy SG7 applies to all sites. In doing so the policy itself needs to be reformatted and revised wording/format is provided by ECC for CBC in Appendix 1.

3.57 The Draft Plan includes 22 development management policies, reduced from 28 at the Preferred Options stage. These policies provide detail guiding the development management process (planning applications). The policies set out how development will be managed to ensure that it contributes towards the Local Plan’s vision and objectives, via the strategic framework put in place by the policies contained in Section 1 and those covering Sustainable Growth, Climate Change, Environmental Assets and Places in Section 2.

3.58 CBC has amended its affordable housing target from 20% to 30% on the evidence of the Strategic Housing Market Assessment together with new work carried for the Whole Plan Viability Assessment. The latter establishes that 30% is broadly viable in the current economic climate. Further work will be carried out to determine an appropriate level and mix of affordable housing in the new Garden Communities.

3.59 At the Preferred Options stage ECC made various representations on the development policies. The changes have largely been accepted and of note include reference to the ECC Independent Living Programme (Policy DM10 - Housing Diversity), and a revised and more succinct Policy DM25 - Surface Water Management, following further engagement with ECC as Lead Local Flood Authority.

3.60 It is recommended that both Policies DM2: Community Facilities and DM3: Education Provision are amended. Policy DM2 should exempt State funded schools and DM3 needs to change its focus so that it is positively worded to facilitate delivery. This would ensure compliance with the NPPF. As currently worded, both policies could prevent the relocation of a school into new buildings or the sale of an asset to fund improved education services. The changes will also ensure consistency between Policies DM2 and DM3.

3.61 It is recommended that a minor change is made to the explanatory text and Policy DM22: Parking to correct terminology.

3.62 It is recommended that the Draft Plan’s Policies Map shows a range of environmental designations that are omitted such as the Abberton Reservoir and the Stour and Orwell Estuaries SPAs as these are statutory sites.

Policy objectives

3.63 ECC aims to ensure that local strategies and policies provide the greatest benefit to deliver a buoyant economy for the existing and future population that live, work, visit and invest in Essex. As a result ECC is keen to understand and support the

formulation of the development strategy and policies delivered by Local Planning Authorities. Involvement is necessary because of the ECC role as: a. a key partner within Greater Essex and the Haven Gateway Partnership promoting economic development, regeneration, infrastructure delivery and new development throughout the County; b. major provider of a wide range of local government services throughout the county of Essex; c. the strategic highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan and as the local highway authority; Local Education Authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; and lead advisors on Public Health; and d. an infrastructure funding partner, that seeks to ensure that the development allocations proposed are realistic and do not place an unnecessary cost burden on ECCs Capital Programme.

3.64 The ECC response seeks to ensure the following ECC policy objectives are reflected in CBC’s Draft Plan:  Essex Organisation Strategy, 2017-21  Economic Plan for Essex (2014)  Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)  ECC Independent Living Programme (May 2016)  ECC Developers’ Guide to Infrastructure Contributions (2016)  Essex Minerals Local Plan (2014)  Essex and Southend-on-Sea Waste Local Plan (2017)  Greater Essex Growth and Infrastructure Framework (2016)  Commissioning School Places in Essex 2016-2021.

4. Options

4.1 The full proposed ECC response to the latest stage of consultation is set out in Appendix 1 to this report. It is recommended that these comments form the basis for ECC’s written representations to be submitted to the Planning Inspector appointed to conduct the independent Examination in Public into the Local Plan. The Inspector’s role is to assess whether the plan has been prepared in accordance with the Duty to Cooperate, legal and procedural requirements, and whether it is sound. The formal ECC response to the Draft Plan only includes those areas where an amendment is required to update information, clarify intent or ensure soundness in accordance with the NPPF.

Duty to Cooperate

4.2 CBC has worked collaboratively with ECC throughout the preparation of the Draft Plan, particularly in the period following the Preferred Options consultation in 2016. This can be demonstrated through a range of CBC and ECC officer meetings, the procurement and contribution to the evidence base to support plan preparation (notably transport modelling and the CBC Infrastructure Delivery Plan), and through the North Essex Garden Communities meetings. Issues were identified, discussed and appropriate action taken to reflect requirements and address concerns within the Draft Plan and the supporting evidence base.

4.3 ECC is satisfied that CBC has met the duty to cooperate requirements with ECC under Section 110 of the Localism Act. This covers ECC’s role as Minerals and Waste Planning Authority, Local Education Authority, Highways Authority and Lead Local Flood Authority. However, it is recommended that amendments are made to certain policies to ensure effective delivery. Engagement has also taken place in terms of ECC’s role promoting economic development, regeneration, and infrastructure delivery; as lead advisors on Public Health; as a major provider of a wide range of local government services; and as an infrastructure partner, that will seek to ensure that the development allocations proposed are properly funded by the proposed development, realistic and do not place an unnecessary (or unacceptable) cost burden on ECC’s ability to deliver unfunded infrastructure.

4.4 It is recommended that ECC continue to work collaboratively with CBC to progress the Draft Plan through to submission and then examination in public. This is likely to focus on updates to the transport modelling and further assistance on the CBC IDP.

4.5 As regards highway matters ECC has assisted the preparation of the Draft Plan through joint meetings with CBC and where relevant Highways England, and has prepared transport modelling reports to identify impacts and required mitigation, where possible. Appropriate policies have been included in the Draft Plan with a focus on the Colchester urban area. Additional discussions with the North Essex Authorities have also considered the cross border impacts of growth identified in the emerging new Garden Communities. ECC will continue to be involved in any update required to the evidence base as the Draft Plan moves to submission.

4.6 It is recommended that ECC acknowledge and support references made to the Minerals and Waste Local Plans, including the need to reference Minerals Safeguarding Areas in the Garden Communities policies in Section 1. A minor amendment is needed to correctly refer to the now adopted Waste Local Plan.

4.7 It is recommended that ECC continue to assist CBC in identifying requirements arising from their growth proposals and provide the necessary updates to the CBC IDP.

4.8 In relation to the Garden Communities across the county, collaborative work is progressing between BDC/Uttlesford District Council (UDC) and ECC regarding the West Braintree Garden Community, and the potential incorporation of adjoining land in Uttlesford District. The Draft Uttlesford Local Plan (Regulation 18) was considered by UDC members on 11 July and was published on 12 July for public consultation until 4 September 2017. The Draft Plan promotes a cross boundary new Garden Community adjacent to the proposed West Braintree Garden Community allocation, with the land located within Uttlesford district land expected to comprise a minimum of 970 new homes up to 2033. Moving forward, as with the separate proposals affecting Colchester, the relevant LPAs and ECC will need to ensure the Garden Community planned for this location is jointly masterplanned and delivered to provide a coherent quality place in which to live, work and enjoy.

Legal and procedural requirements including ‘soundness’

4.9 Paragraph 182 of the NPPF states a local planning authority should submit a plan for examination which it considers is ‘sound’ – namely that it is positively prepared,

justified, effective and consistent with national policy. Compliance is examined below:

a. ‘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’.

4.10 ECC response

It is recommended that ECC acknowledge and support CBC’s work that seeks to meet its objectively assessed housing need in full over the plan period within its administrative boundaries. CBC is seeking to deliver 920 homes pa and a total of 18,400 over the Plan Period. For the period 2017-2033 a land supply of 15,078 new homes has been identified or 16.4 years. For CBC the spatial strategy includes provision for two new cross boundary Garden Communities to the east and west of the Colchester urban area adjoining Tendring and Braintree District. The Draft Plan does not account for any unmet requirements from neighbouring authorities, however significant joint working has taken place between the North Essex Authorities to ensure housing need can be met within each authority supported by employment opportunities and infrastructure.

It is recommended that ECC acknowledge and support job forecasts and employment land requirements contained in the Draft Plan. In accordance with national planning policy and guidance, the CBC evidence base includes economic forecasts together with demographic projections to establish the inter- relationship between population growth, forecasts of new jobs and the number of new homes needed to accommodate these levels of growth. The annual job forecast is 920 and for class B use employment land, a range of 22 to 55.8 ha over the Plan Period. An employment land review has been undertaken in accordance with national planning policy and guidance.

An amendment is required to Policy SC2: Middlewick to ensure that 3 ha of land is provided for a new primary school and associated early years and childcare facility to be secured through Section 106 Town and Country Planning Act 1990 obligations, together with associated financial contributions. As stated in paragraph 4.7, it is recommended that ECC continue to assist CBC in preparing their IDP before submission.

The second requirement in NPPF paragraph 182 is:

b. Justified – ‘the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence’.

4.11 ECC response

It is recommended that ECC support the spatial strategy as outlined in the Draft Plan. The spatial strategy put forward by CBC reflects the outcome of Sustainability Appraisal work, the overall evidence base, deliverability considerations, the availability of development sites, and an overall evaluation

of the combination of allocations and policies that collectively it considers produce the most sustainable pattern of growth. This covers employment and housing allocations. CBC state that the evidence base concluded that new settlement options were only acceptable if promoted as Garden Communities and that there needed to be a combination of communities across the three planning authority areas - Braintree, Colchester and Tendring (as outlined in Section 1 of the Local Plan and discussed earlier).

The Draft Plan is the product of an evidence-based process in line with national regulations, policy and guidance. The evidence base supports both Section 1 and Section 2 of the Draft Plan. This covers, but is not limited to, a range of topics such as housing, employment, retail, garden communities, transport, infrastructure (green, social and physical), environment, flooding and viability.

The third requirement in NPPF paragraph 182 is:

c. Effective – ‘the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities’.

4.12 ECC response

It is recommended that ECC acknowledge and support the joint working on cross-boundary strategic priorities that has taken place throughout plan preparation. ECC is a signatory, along with North Essex districts, and Chelmsford City Council, to the ‘Memorandum of Co-operation: Collaboration on Strategic Priorities in North and Central Essex’ (FP/470/04/16), regarding the exploration of the potential for new garden communities across the area and other strategic cross boundary matters.

ECC will continue to be an active and equal partner of a number of member and officer working groups regarding the North Essex Garden Communities proposals to progress their planning and delivery.

Local Development Vehicles are being recommended as a way of delivering each Garden Community. Such arrangements would involve ECC. Being locally driven will ensure that infrastructure, facilities and services will be put in place when they are needed and seek to ensure that land is released for housing, employment, retail and other uses. The Draft Plan states: ‘Establishment at an early stage in the development of the garden communities, of appropriate and sustainable long-term governance and stewardship arrangements for community assets including green space, public realm areas and community and other relevant facilities; such arrangements to be funded by the developments and include community representation to ensure residents have a stake in the long term development, stewardship and management of their community.’ The three LPAs together with ECC are confident that a Local Development Vehicle model is viable and can deliver successful and sustainable garden communities, but will continue to explore other ways of achieving the vision that offer similar levels of confidence that the right quality of development and supporting infrastructure will be delivered at the right time.

A Memorandum of Understanding has also been signed between ECC, Colchester BC, University of Essex, and Tendring DC, which sets a framework for collaboration between parties in order to promote the economic interests and prosperity of North East Essex (April 2014). The MOU was supplemented in March 2015 to clarify joint strategic objectives and justify investing further time and resources into developing proposals for a potential new garden village (i.e. Garden Community).

ECC has and will continue to maintain close working relationships with the DfT, HE and the LPAs to facilitate the delivery of important strategic highway projects, namely A12 and A120. The A12 scheme to widen the road between junctions 19 (Boreham) and 25 (Marks Tey) is within a committed government programme (Road Investment Strategy (RIS1)) to begin construction by March 2020. HE consulted on options in January to March 2017, and is now developing a preferred option to take forward to Development Consent Order (DCO). In March 2017 ECC completed an options consultation on potential routes for the A120 for that section between Braintree and the A12. ECC will recommend a preference to Government in autumn 2017. ECC and partners will lobby DfT and Government for the project to be included in the Road Investment Strategy (RIS2), which will run from 2020 - 2025. Any improvements to both the A12 and A120 would be likely to overall have a significant positive effect on traffic and transport across the District, and North Essex, in the plan period.

As noted in paragraph 4.7 above, ECC will continue to assist CBC in identifying requirements arising from their growth proposals and provide the necessary updates to the CBC IDP, to ensure deliverability.

The fourth requirement in NPPF paragraph 182 is:

d. Consistent with national policy – ‘the plan should enable the delivery of sustainable development in accordance with the policies in the Framework’.

4.13 ECC response

ECC has ensured its representations and ongoing engagement with CBC throughout plan preparation address ECC’s areas of responsibility consistent with national policy to enable sustainable development. The ECC response to the Draft Plan recommends several areas for clarification to enable effective delivery and amendments to improve policy and explanatory text. ECC will work cooperatively with CBC to ensure issues can be positively addressed prior to CBC submitting the Draft Plan for examination. A Statement of Common Ground may need to be prepared at that time to address any outstanding issues. The approach will be confirmed closer to the time.

5. The following documents have been used to inform the ECC response (web-links provided).

 Colchester Publication Draft Local Plan, June 2017  Colchester Publication Draft Local Plan Sustainability Appraisal Report (Section 1)

 Colchester Publication Draft Local Plan Sustainability Appraisal Report (Section 2)  Colchester Local Plan Transport Modelling, May 2017  North Essex Garden Communities Employment & Demographic Studies  National Planning Policy Framework  National Planning Policy Framework (2012)  Planning Policy Guidance (2014)  Essex Organisation Strategy, 2017-21  Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)  Super Fast Essex Broadband  ECC Developers’ Guide to Infrastructure Contributions  ECC SuDS Design Guide  ECC Independent Living Position Statement, September 2016

6. Issues for consideration

Financial implications:

6.1.1 There are no direct financial implications in respect of ECC’s response to the consultation. However, there will be implications for ECC’s financial position to assist implementation of the Draft Plan once adopted. The Draft Plan triggers infrastructure delivery when sites are brought forward for development. Site specific policies and ‘infrastructure delivery and impact mitigation’ policies cover ECC requirements to make the development acceptable in planning terms. An Infrastructure Delivery Plan has been prepared to support Local Plan delivery. ECC has assisted CBC in the preparation of this document outlining the infrastructure requirements arising as a direct result of Local Plan growth. Funding sources include but are not limited to Section 106, CIL (where adopted), Section 278 works (highway matters), Highways England, and South East Local Enterprise Partnership.

6.1.2 ECC has and will continue to maintain close working relationships with the Department for Transport (DfT), HE and the LPAs to facilitate the delivery of important strategic highway projects, namely A120 and A12.

6.1.3 In terms of the Garden Communities, Local Development Vehicles are being recommended as a way of delivering each Garden Community. Such arrangements would involve ECC. This approach was supported by ECC Cabinet in December 2016 (FP/642/11/16). The three LPAs together with ECC are confident that a Local Development Vehicle model is viable and can deliver successful and sustainable garden communities, but will continue to explore other ways of achieving the vision that offer similar levels of confidence that the right quality of development will be delivered at the right time.

6.1.4 Policy SG7 (Infrastructure Delivery and Impact Mitigation) requires all new development to be supported by, and have good access to, all necessary infrastructure. Planning permission will only be granted if it can be demonstrated that there is sufficient appropriate infrastructure capacity to support the development or that such capacity will be delivered by the proposal. It must further be demonstrated that such capacity as is required will prove sustainable over time both in physical and financial terms. Developers will be expected to contribute

towards the delivery of relevant infrastructure. They will either make direct provision or will contribute towards the provision of local and strategic infrastructure required by the development either alone or cumulatively with other developments.

6.1.5 This is supplemented by Policy PP1 (Generic Infrastructure and Mitigation Requirements) an overarching policy for the place specific policies. The policy states that in addition to site specific requirements identified in relevant policies, all proposals will be required to make contributions to the cost of infrastructure improvements and/or community facilities as required and supported by up-to-date evidence from appropriate sources including the Infrastructure Delivery Plan (IDP), Parish Council, or specially commissioned work. Contributions will be secured to an appropriate level by way of legal agreement or through CIL as required. The policy covers relevant matters for ECC such as appropriate SuDS for managing surface water runoff within the overall design and layout of the site; proportionate mitigation for area-wide transport issues within the Colchester urban area; and safe pedestrian access from the site to existing footways to enhance connectivity.

Legal implications:

6.2.1 The duty to co-operate is contained in the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011. It requires Local Planning Authorities to engage constructively, actively and on an on-going basis to ensure that the preparation of the Local Plan has regard to key strategic matters addressing social, environmental and economic issues which can only be addressed by effectively working with other authorities beyond their own administrative boundaries. This is echoed in paragraphs 178-181 of the NPPF.

6.2.2 Guidance issued on 6 March 2014 stresses that close cooperation between District Councils and County Councils in two tier areas will be critical to ensure that both tiers are effective when planning for strategic matters.

6.2.3 As recorded in section 4.11 of this CMA, ECC entered into a relevant MOU to ensure this took place.

6.2.4 Although a Local Plan may be found unsound at Examination if the duty to cooperate has not been properly undertaken and the implications of this require careful consideration, the duty is not a duty to reach agreement. ECC is carrying out its functions properly in submitting comments on specific issues of concern or objection, where necessary, at this stage.

6.2.5 Other issues which the inspector may need to consider on soundness are summarised in sections 4.2 – 4.13.

7. Equality and Diversity implications

7.1 The Public Sector Equality Duty applies to ECC when it makes decisions. The duty requires us to have regard to the need to: a. Eliminate unlawful discrimination, harassment and victimisation and other behaviour prohibited by the Act. In summary, the Act makes discrimination etc on the grounds of a protected characteristic unlawful

b. Advance equality of opportunity between people who share a protected characteristic and those who do not. c. Foster good relations between people who share a protected characteristic and those who do not, including tackling prejudice and promoting understanding.

7.2 The protected characteristics are age, disability, gender reassignment, pregnancy and maternity, marriage and civil partnership, race, religion or belief, gender, and sexual orientation. The Act states that ‘marriage and civil partnership’ is not a relevant protected characteristic for (b) or (c) although it is relevant for (a).

7.3 An Equality Impact Assessment has been undertaken by CBC to inform the new Local Plan. It concluded that the Local Plan has no negative impacts and there is a low risk of negative impact on the affected groups. Impacts will continue to be monitored and if particular issues are identified, appropriate action will be taken. This could include changes to their consultation approach and activities. It is considered that all opportunities will be taken to advance equality through the Local Plan.

8. List of appendices

8.1 Appendix 1 – full proposed ECC response to the Colchester Publication Draft Local Plan, June 2017.

9. List of Background papers None.

I approve the above recommendations set out above for the reasons set out in the report.

Councillor Cllr David Finch, Leader of the Council 02 August 2017

In consultation with:

Role Date Executive Director for Corporate and Customer Services (S151 Officer)

Nicole Wood Director for Financial Services on behalf of 26 July 2017

Margaret Lee Monitoring Officer

Angela Hutchings, Deputy Monitoring Officer on behalf of 20 July 2017

Paul Turner, Director Legal and Assurance Executive Director, Economy, Localities and Public Health

Graham Thomas Head of Commissioning- Strategic Planning, 10 July 2017 Housing Growth and Development on behalf of

Dominic Collins, Director of Economic Growth and Localities