This Neighbourhood Report provides evidence that the preferred options relating to POLICY SS4: and are UNSOUND.

The report shows that the plan has inadequately met the following tests of soundness. The assessment of the proposed sites is flawed, having not been considered effectively against reasonable alternatives, which are described in the report.

SOUNDNESS TESTS not adequately met:

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

Justified

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

Effective

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

Copford with Easthorpe Neighbourhood Report

April 2017

2 Local Commentary and Response to the Preferred Options proposed by Borough Council (CBC) Prepared by VOICE : Village Opinions in Copford and Easthorpe, a non – political group formed to represent coherently, the views of local people toward the future of the villages of the parish of Copford with Easthorpe This report has been produced in the absence of a formal Neighbourhood Development Plan; a process begun, but subsequently terminated by Copford with Easthorpe Parish Council.

Context

Copford with Easthorpe is positioned with direct connections to road and rail infrastructure. It straddles ancient roads, has 44 listed buildings and an eclectic mix of housing which provides a distinct built environment. A varied natural environment includes ancient fieldscape and natural features, important to the landscape of North . This makes the villages both appealing, yet vulnerable, with an absolute need for careful, sensitive planning. Residents are realistic about the need to consider expansion, which can bring benefits, but determined to ensure that location, infrastructure and density of development are appropriate. The selection of preferred options is considered to be flawed, with too little thought given to alternatives, particularly regeneration of historic property and under-used brown field sites in the parish. A major factor when considering expansion is the very limited capacity for water and sewage at the Copford treatment plant, which is currently over- stretched, with alternative connection to Colchester’s main sewage system, a complex and expensive prospect, irrespective of the location of development within the parish. The report is premised on the underlying assumption that Colchester Borough Council has a notional target of 120 homes to be added to the parish. The following report suggests the location and scale of development to achieve a similar total, with the objective of appropriateness, rather than absolute compliance with this total.

Appraisal of Preferred Options

Hall Road

A key issue is inadequate access and sight-lines at the junction with London Road, for the residential development envisaged. This raises concerns of safety for the increased number of pedestrians and vehicles such development would create. Hall Road is a narrow lane flanked by private garden land, historic banks and retaining walls, with little scope for alteration. There are other sites with better access to amenities including schools and transport links. Inclusion of this site would require major, damaging changes for relatively small gain in the number of dwellings.

Adverse effects on Landscape and Conservation

Hall Road is an ancient route, running from the Old London Road (Stane Street) to the nationally significant Church and hall, from which it is named. Hall Road is a Protected Lane with archaeological significance. Local residents wish that it remains intact throughout its length, maintaining its historic integrity, which planners may not fully recognise.

“Hall Road is of at least Roman origin, being part of a link between Roman Roads 3 and 320. A Roman settlement of some kind lay on Copford Plains, more or less at the midpoint of this link, with access to western and northern Colchester along Road 3 via Hall Road, and southern Colchester along the Easthorpe spur road, Road 320, via Aldercar Road or perhaps via the footpath running from Copford Plains to Gol Grove. Road 320 joins Road 321 on the approach to Colchester” 8

3 CBC’s own account of the valley describes the area as...

“a fieldscape which is ancient in origin” with “an intimate character to the landscape and a sense of tranquillity”. “These landscapes show strong surviving time depth and a richness in both natural and man made landscape features ….The river valley landscape framework should continue to be conserved and enhanced….”3

Hall Road is identified in CBC interactive map as subject to environmental protection policy ENV1 and protected lanes policy DP21. Section 5.10 of the Local Plan also has the; ‘aim to protect open stretches of countryside’. The proposed development is likely to infringe or challenge these policies as well as Natural advice.

“the statutorily desirable object of preserving the character or appearance of an area is achieved either by a positive contribution to preservation or by development which leaves character or appearance unharmed, that is to say, preserved” 4

Adverse effects on the setting of historic and Listed Buildings

Brewers Cottage is a Grade II Listed Building C17th Century, set within a built environment of ribbon distribution, bordering “the ancient fieldscape”. Building development on the Hall Road site will damage that traditional setting. In addition, Keepers Cottage in Hall Road, while not listed, has keen significance as a feature in the landscape setting, which would be damaged by development, as its walls directly abut the roadway of the lane where building is proposed.

“A development which can be seen within a view of a Listed Building lies within the setting of that Listed Building. It cannot therefore be disputed that such a development could potentially affect the setting of the Listed Building……it is necessary not only to consider the Listed Building itself but also the nature and appearance of the existing surroundings of the Listed Building…”6

Adverse Effect on Local amenity and Wildlife Site (LoWS)

The Hall Road site is surrounded on the roadside by hedgerows, which are important habitats for wildlife (5.4 in Local Plan). European protected species such as certain species of bats are likely to use the Hall road site for foraging from the Pits Wood Local Wildlife Site. Arable hedge margins are also a Biodiversity Action Plan habitat. Though lying some distance along the road, the site needs to be seen in connection with Pits Wood. Pits Wood, a LoWS is protected within the local planning system. Such areas are a ‘material consideration’ in the determination of planning applications.7 It is argued that development of the Hall Road site will have an adverse effect on this LoW and its distinct amenity, which is highly valued and enjoyed as a precious, ancient country walkway.

“together with statutory protected areas, LoWS represent the minimum habitat we need to protect in order to maintain the current levels of wildlife in Essex”7

1 Colchester Borough Historic Environment Character Project 2009. 3.1.12 p67 2 Review of Countryside Conservation Areas in Colchester Borough August 2005. 2 AWooded Roman River Valley 3 Ibid. 4.2;2; Roman River Valley Landscape 4 https://historicengland.org.uk/advice/hpg/decisionmaking/legalrequirements 5http://planningni.gov.uk/index/policy/planning_statements/ppso6_conservation_areas/ppso6_policy_bh12.ht m 6 http://planninglawblog.blogspot.co.uk/2013/03/listed-buildings-and-their-setting.html 5 7 http://www.essexwt.org.uk/protecting-wildlife/local-wildlife-sites 8 Hall Road in Copford’s Archaeological landscape N Crummy 2017

4 Queensberry Avenue

Major concerns have been raised by residents, about the number of homes, their density and access. Homeowners wish to bring the issues below to the attention of planners, for which there needs to be further consideration and dialogue. The proposed site was not in the call for sites, but was identified through the Strategic Land Assessment. This has left residents worried about the extent to which their concerns are understood.

Adverse effects on traffic flow and safety, including access to Copford primary school

The single access road through the existing development is 5.5m wide, classed as a ‘Type 3’ feeder road with a design capacity to serve 200 homes. There are 156 houses, leaving theoretical capacity for 44 additional homes, rather than the 70 proposed. For more than 44 homes to be allocated to this site, further road access should be provided which might be accommodated in land to the North of the site, which could be designed to meet the London Road. In addition, there is major concern for the safety and prolonged disruption which construction traffic would pose unless alternative access is provided.

Consideration should be given to a detailed traffic review including potential roundabout and traffic calming features where connecting roads meet London Road. Such review should include an assessment of air quality on pedestrian routes, used by children and families walking to school when traffic congestion is at its peak. Assessment should include the Public Rights of Way at Queensberry Avenue and Foundry Lane.

Adverse effects on wildlife The wooded land and pasture adjacent to and included within the proposed site are directly connected to the Roman River. The concerns raised over the proposed Hall Road site are shared for the Queensberry proposal. In particular there is a line of mature trees-c100 years old-which might be affected and associated wildlife including colonies of bats. Proper review of impact on woodland habitat and adjacency to the Roman River need to be properly assessed and residents consulted about impact.

Alternative Sites The VOICE group has three sources of local views: 1 Survey conducted by the Neighbourhood Development Group, subsequently disbanded by the parish council. 2 An open day, attended by 125 local people. 3 Submissions to the CBC preferred options consultation.

This evidence collectively shows recurring themes based on the need to seek alternative sites beyond and including the preferred sites identified and to ensure a high quality of design and environment. They are summarised below

Brownfield land National planning policy highlights the need to look at brownfield options first, considering development of green belt as a last resort, only if it can be justified. There are brownfield sites within the parish as well as areas of greenfield with lower environmental value that would be viable, available options for development. There are four key areas of commercial; ‘brown’ land along London Road: 1The mixed trading estate 2The under-used BT Telephone Exchange building with associated land 3 The mixed, light industry at the end of Foundry Lane 4 The car boot sale site (discussed separately below)

5 While these are all in private ownership, the incentive of ‘change of use’ status could provide the opportunity for owners to make some of this land available in the lifetime of the local plan. There is also, a substantial area of vacant grass field behind the commercial estate, for which an assessment of change of use and an extension to the village line by planners would be helpful.

Car boot sale site Despite the willingness of the landowner to develop this site, earlier planning applications having been rejected on the grounds of upholding the policy of rural separation. Discussions with the landowner indicate a reduced ambition of scale, with a proposal for some 40 houses, with a parkland area, lake and sound-reducing barrier where the site meets the A12. The housing could be blended into the Copford development, with a high value country park amenity creating the rural separation between and Copford. The revised proposal would retain the clear separation between the two parishes, add houses to the overall development figure, while considerably improving the visual landscape and leisure amenity of the area. Early discussions suggest there is a shared appetite for such a development. The site is brownfield, being excavated in the 1960’s for construction of the Marks Tey/Stanway by pass. Its inclusion would help meet the Council’s compliance with the national policy of using brownfield land wherever possible.

Copford Place Copford place is a late 17th century manor house with grade 2 listed status and high local significance. Its adjacent stable block is also listed. The fabric of the building is in a poor state of repair, but has huge potential to be the centre of an ambitious housing and regeneration scheme. Land adjacent to Copford Place, stretching some distance behind the house, could be developed to provide a significant number of homes of mixed character and size, to include apartments and houses. If approached imaginatively, the development would accommodate mixed use, including protected spaces for elderly residents, small households and family homes. When seen together, this historic site would be returned to the street scene as a key part of the village landscape and would be acclaimed similarly to comparable schemes at Colchester Garrison and Copford Lodge (the former nightclub site). Copford place would further balance the scale of development across the village. However, development needs to leave the Roman River area intact, which would add further to the country parkland amenity of the parish.

Further sites identified in the ‘Call for Sites’ There are parcels of land identified within the call for sites, which have been ignored, yet show far greater potential for modest scale, sustainable development. Some areas identified have advantages over the preferred options:

1. Unlike Hall Road, they are on existing roads, so create no access problems. 2. There will be less access and construction pressure than is required for large scale development at the Queensberry site 3. They are within easy walking distance from Copford Primary School, enabling healthy, safe travel to school with no environmental impact. 4. If each of these sites were developed to a small scale, they would enable all identified development sites to maintain a smaller size, reducing pressures previously identified

6 Drainage and water Issues identified in Copford by Anglian Water receive a red RAG rating. Copford sewage works cannot meet existing demand. The proposed scale of development would need major engineering and connection to the Colchester system. The scale and disruption of such civil engineering, coupled with house construction is of major concern to residents.

Landscaping and house types The street scene in most areas of Copford and Easthorpe is characterised by an eclectic mix of house types, grass verges, trees and front gardens. In the February 2016 village survey, people were asked what, if anything, would improve the current street scene. The two most common suggestions were to reduce on-street parking and to plant more trees.

At the public consultation in March 2017 the connection between the increase in slow moving traffic within the parish and the deterioration in air quality was raised. The planting of more trees was generally accepted as a means to help mitigate the effects of any increase in pollution.

Evidence in consultation shows that residents of Copford and Easthorpe wish to ensure a high quality of environment, including:  enough off-street parking for the number of adults expected to live in each individual property  front gardens for each property  grass verges and trees.

When questioned about the range of housing needs, residents expressed clearly that they wish to see a full mix of provision including:  affordable homes for young buyers  homes targeted on older people down-sizing  high quality family homes.

Transport and infrastructure Some key features and problems associated with transport and infrastructure have appeared during consultations:

Volume and sluggish movement of traffic, safety and Air Quality Consultations have shown major concern that the existing road and transport infrastructure is not coping with current demand, which does not bode well for the increasing pressures, which will inevitably arise from the developments envisaged.

 Development of Tollgate area is producing increased volume of traffic, particularly at Peak times  Slower moving traffic is proven to produce higher levels of harmful gasses, particularly from diesel engines. A large number of very large commercial vehicles now using London Road, meaning that increases in the most harmful Nitrogen Dioxide from their very large diesel engines, is inevitable. We recommend that air quality monitoring is established as part of the planning evidence base  Increased use of Marks Tey Station and inadequate parking at the station is resulting in high volumes of all-day parking, particularly in London Road, with increased danger to pedestrians, including children walking to school at peak times

7  The heaviest vehicles using London Road will cause disproportionate damage to the road, including the architecturally important 18C Stanway Bridge, which is a listed building (Listing NGR: TL9322823999) for which there is a duty of protection. In addition, London Road includes a large proportion of traditionally built, period properties with shallow footings and traditional brickwork, which are often 3.5 – 8 metres from the roadway of London Road, including a significant number of listed buildings. As such, they are particularly susceptible to damage from long-term vibration from such vehicles.  Marks Tey railway station serves a large catchment, including Copford and Easthorpe , with a rising volume of passengers as the local population has grown and expanded. The total in 2016 was 523,000 (1432 per day), which will inevitably rise with the proposed house building in the next 5 years.  Current facilities at the station and size of trains are barely coping with current numbers. Planners need to make a realistic evaluation of these factors when considering the projected increase in commuter population in the proposed housing development.  It is apparent that there is poor access for disabled commuters. This issue is not confined to Network Rail and should be considered within the planning demands in proposed development, for example in parking for disabled travellers in a ‘front door, to train door’ approach.

Practical steps are proposed, which we recommend that planners evaluate with some urgency

 Design all road schemes to include additional access to Queensberry Avenue and its potential termination on London Road at a mini-roundabout. This would in turn create a traffic calming and weight restriction to protect residents, the road surface and the listed Stanway Bridge  Commence early negotiations with the owner of car parking at Marks Tey Station and adjacent land owners, to develop a high capacity, high-deck parking area, consistent with many other stations on the same line  Consider using the unusual, inherited width of the London Road to become an environmental advantage, further encouraging its use by pedestrians and cyclists as a ‘Green Route’ to schools, Marks Tey station, other villages and Colchester. Such re- evaluation would include:

1. prevention of dangerous, unnecessary use by very large commercial vehicles 2. discouragement of day-parking on London Road 3. improvement of safe cycle and pedestrian access through the narrow section of the London Road passing through Marks Tey 4. improved cycle and pedestrian routes from London Road, throughout the interchange system to Marks Tey station 5. Evaluation of bus access as part of a mobility and ‘Green Commuting’ approach to infrastructure planning

8