APPENDIX 1

Chelmsford Draft Local Plan Preferred Options Consultation Feedback Initial Note

July 2017

Our Planning Strategy to 2036

Local Plan

Appendix 1

Local Plan Preferred Options Consultation Feedback Note

This note sets out the main issues raised in the consultation responses from a number of Specific and Duty to Cooperate Consultation Bodies and General Consultation Bodies. It also summarises the key points made by visitors to the public drop-in exhibitions.

A full Feedback Report will be published in due course. This will summarise the main issues raised in all the representations received (including from members of the public, landowners and developers), summarise the Council’s response to them and detail changes made to the Local Plan. It will also give more details on the consultation and engagement activities undertaken aimed at maximising awareness and involvement.

The main issue tables by respondents are presented in the following order:

• Essex County Council and Local Planning Authorities • Education Consultees • Utility Consultees • Environmental & Health Consultees • Transport Consultees • Health Consultees • Sport Consultees • Parish Councils within Chelmsford City Council’s area • Adjoining Parish Councils • Resident/Community Associations • Key points raised by visitors to the drop-in exhibitions.

Abbreviations

CCC Chelmsford City Council CNE Bypass Chelmsford North East Bypass CIL Community Infrastructure Levy DTC Duty to Cooperate ECC Essex County Council FAS Flood Alleviation Scheme FZ Flood Zone GB Green Belt HRA Habitats Regulations Assessment HMA Housing Market Area IDP Infrastructure Delivery Plan LPAs Local Planning Authorities MRA Minerals Resource Assessment NPPF National Planning Policy Framework OAN/OAHN Objectively Assessed (Housing) Needs PM Proposals Map PO Preferred Options RJ Reasoned Justification Appendix 1

SA Sustainability Appraisal RDR2 Radial Distributor Road 2 SHMA Strategic Housing Market Assessment SGS/SG site Strategic Growth Site SPA Special Policy Area SFRA Strategic Flood Risk Assessment SuDS Sustainable Urban Drainage Systems SWF South Woodham Ferrers TCPA Town and Country Planning Association VDS Village Design Statement WCS Water Cycle Study

Essex County Council and Local Planning Authorities

Essex County Council (ECC)

Site or topic Main Issues General ECC supports: • the focus for growth • allocation of brownfield sites to bring forward regeneration and sustainable travel • greenfield communities to maximise delivery or financial contributions for infrastructure • Green Wedges and Corridors to maximise walking/cycling • partnership working Minerals Plan • Developers are required to undertake a Minerals Resource Assessment (MRA) on sites 3a, 3b, 4, 5, 6. ECC wishes to be involved in masterplanning involving mineral issues • The MRA assesses whether minerals are present and viable for extraction prior to development • Text suggested for adding to policies • Site 2 has been subject to a MRA, without objection. Strategic Priorities Support, with the following: • Inclusion of reference to independent living for older people at 3.4 and 3.5 • Consideration of a ‘zero rate’ allocation to Strategic Growth/Growth Sites to maximise infrastructure contributions from developers (3.26) Spatial Principles • Seeks reference to ECC, as Highway Authority, to investigate any future strategically and locally important transport infrastructure to meet longer term growth, e.g. Eastern Gateway Access Road (EGAR) Strategic Policy S5 • Add reference to the Historic Environment Record Strategic Policy S7 • Recommend policy is amended to provide some flexibility for the most appropriate use, rather than retaining facilities for their own sake. Appendix 1

• Encourage inclusion of criteria for assessment of viability, alternative uses, and appropriate marketing. Strategic Policy S8 & • Recommends consideration of inclusion/allocation of dedicated S11 ‘grow on space’ Strategic Policy S9 • Must work together to create a Chelmsford North East Bypass (CNE Bypass) scheme which can be delivered well within the next plan period • Delivery of schemes will involve attracting Government funding; infrastructure investment will exceed ECC and Chelmsford City Council (CCC) capacity • Beaulieu Park station is dependent on Network Rail prioritisation; considerable work needed to achieve delivery by 2022 • Creation of additional capacity is needed to facilitate reduction in number of vehicles coming into city – through CNE Bypass, enhanced junction 19, widening of A12 to junction 17. A12 widening will be a partnership with Highways England. • Significant modal shift is necessary, with investment in improved facilities – but behavioural and cultural change will need to be a further focus for co-operation Alternative site – • Acknowledges this is not supported by the evidence base Hammonds Farm • Proposed growth would need a detailed assessment of the traffic impact to A12 junction 18 and the A12 itself, plus mitigation. • Would be detached from urban area • Additional Park and Ride related to Hammonds Farm may jeopardise viability of existing and proposed P&R sites • Travel to new station would be along A12 which is already congested, rat running would not be acceptable. • NE Chelmsford a better location than Hammonds Farm in transportation terms – choice of routes, use of Beaulieu station Strategic Policy S12 Parking • CCC Car parking strategy will need to align with ECCs Future Transport Network concept. • Parking at proposed allocations should consider the impact on citywide travel patterns. Buses • Notes on bus transport including bus station capacity being at 160% of planned use, ECC investigating the potential to increase capacity, and also notes accessible transport provided by Chelmsford Community transport. Park and Ride (P&R) • Further work required to review P&R strategy for existing and proposed sites, and modelling will be a part of this. • Clarification sought on new P&R for west Chelmsford – related to existing area of search, or A1060? Also the purpose of a site Appendix 1

at Beaulieu station. Exact locations will need to be considered to enable business cases to be developed. Site 3b & Site 4 • Require land to be safeguarded for potential extension to existing P&R sites Strategic Policy S13 • ECC has prepared an exemplar policy for developer contributions and CIL to encourage consistency, and provides recommended wording Strategic Policy S14 • ECC is developing a vision for green space. Welcomes the opportunities in the Plan, and welcomes discussions on links to other green networks beyond CCC boundary and optimising accessibility to green spaces. Table 11 • Strategic Growth Sites 4, 6a and 6b are within 250m of safeguarded minerals sites, so ECC should be consulted at application stage and this should be noted in the allocation Table 11 • Currently sufficient waste sites available for first 5 years of growth. New Municipal Waste Strategy expected to be adopted around 2023. All allocated sites • Should be a requirement for involving the local community in bringing forward all future development proposals, not limited to selected site allocations. • Wider pedestrian/cycle links will involve discussions with adjacent landowners, this should be noted Strategic Growth Site • Provides detail to inform re-phasing and mitigation for mineral 4 extraction on and adjacent to the allocation, including distance from operations, noise, access, delivery of CNE Bypass. Strategic Growth Site • Provides detail to inform re-phasing and mitigation for mineral 5 extraction on and adjacent to the allocation, including distance from operations, noise, access. Text amendment suggested to reflect potential need for re-phasing of adjacent quarry site. Strategic Growth Site • Although main access will be from B1418 other access points 8 need to considered and modelled as part of any transport assessment by developer • Mitigation measures identified through traffic modelling should be delivered as early as possible • Designation of business floorspace as flexible should not only be at this location but others too. Opportunity Site • ECC should be consulted on any development proposals, OS1c adjacent to the minerals transhipment site Policy SPA2 • ECC should be consulted on any development proposals, adjacent to the minerals site Policy HO1 • Would benefit from adding specific reference to Independent Living requirements, and adding that to policy text Policy EM1 • Would welcome engagement with CCC on appropriate and viable proposals to ensure flexible employment space including ‘grow-on space’. (See also S8, S11 above) Appendix 1

Policy CO3 • Recommend additional criteria in Section A for education and community uses (similar to iv in CO2) Policy HE1, HE2, HE3 • Splitting into these three categories does not reflect the NPPF. ECC welcomes discussion with CCC to remedy this – suggests Designated Heritage Assets, Non-Designated Heritage Assets, Archaeology (which should also reflect Essex Historic Environment Record) • Further clarification required for para 8.98 – ‘in some circumstances’ – which could be misleading Policy MP1 • Although mentioned there is no specific policy on health and well-being. This may not be necessary but ECC can give advice if this is added. • SA could make reference to more up to date information (2016) to supplement 20212 evidence. • Recommend consideration of 10 principles in Sport England’s Active Design Principles. Policy MP7 • Recommend strengthening para 9.33 of the RJ to compel developers to engage (text suggested) • Text amendment at 9.34 to pre-empt connectivity • Remove reference to BT Exchange (others are available), (text suggested) Evidence base • Several useful links given to further documents for public health local plan evidence SuDS • Additional list of sites where SuDS are recommended to be installed to improve drainage and maximise runoff attenuation, or flood management measures are included, as follows: 1d, 1e, 1i, 1m, 1p, EC3, EC4, 8 • Sites which must demonstrate capacity for water flows elsewhere on site, as follows: 1g, 1c, 1h, 1n, CW1c, CW1d, CW1e, Sites which must allow sufficient easement for maintenance to watercourses, as follows: 6a

Basildon Borough Council

Site or topic Main Issues Strategic Policy S8 • Object to the statement that the 20% buffer is there to meet Development only CCC’s housing need - not in the spirit of DTC. requirements • Need to consider travel to work areas as well as HMA – should undertake further work including with those outside HMA/in other HMAs to determine if CCC can help to meet their unmet needs. • Seek to clarify figures, they make the total 22,218 rather than 22,1212 Appendix 1

Strategic Policy S12 • Seeks further discussion on A132 improvement proposals Infrastructure before the Local Plan is finalised. requirements • Transport modelling for SWF should make realistic assumptions about modal shift. • Other improvements will be needed, e.g. at Rettendon Turnpike and wider network of A127 & A130. G&T • CCC should take a cautious approach to Gypsy and Traveller and Travelling Showpeople provision, in advance of full Gypsy & Traveller Accommodation Assessment being published. • Basildon’s need is being assessed separately, and cannot confirm any unmet need – it has been unable to meet its need previously. • Seek to continue to work with CCC under DTC. DTC • Welcomes further engagement particularly on cumulative highway impacts, strategic transport, Gypsy and Traveller provision.

Braintree District Council

Site or topic Main Issues General • Have had positive and wide-ranging DTC discussions. Of particular interest are growth at Great Leighs, CNE Bypass, and railway station and P&R at Boreham. Further positive and ongoing dialogue is welcome. • Will wish to comment on the IDP. Strategic Policy S12 • Braintree growth will require significant infrastructure in its Infrastructure own right, which could limit contributions on major requirements infrastructure projects outside the district, and impact on viability. • No information to suggest that Braintree growth is dependent on provision of the CNE Bypass. • Would not wish to see the new railway station impacting negatively on Hatfield Peverel station or Braintree Branch Line – looking to improve these to enhance sustainability. Growth Area 5 Great • Need to co-ordinate growth here with Braintree growth, Leighs particularly education. • Any retail proposal should include an impact assessment on retail at Great Notley, and that proposed at East of London Road, Black Notley

Appendix 1

Brentwood Borough Council

Site or topic Main Issues Regional context • Although Brentwood does not share a HMA with Chelmsford, there are strong links between the boroughs Strategic Policy S8 • Supports S8 and Chelmsford being able to meet its needs in full Development requirements Strategic Policy S12 • Supports joint efforts to secure investment and deliver Infrastructure improved road infrastructure, including A12, as a significant requirements cross-boundary issues for Essex & SE England. DTC • Welcomes the opportunity to continue with the DTC

Castle Point Borough Council

Site or topic Main Issues General • Support the preferred spatial development strategy described in the Plan Housing Needs • Requests CCC assist Castle Point in meeting some of its identified housing needs – setting out evidence to support the request. A demonstrable link between south Essex and Chelmsford exists, which justifies the request. Improvements to • Welcomes support for improvements to the A130, particularly the A130 Fair Glen interchange with the A127. Landscape corridor • Welcomes recognition of significance of the landscape corridor A130 and commitment to playing part in reviewing policy and guidance including its role in the separation of settlements.

Colchester Borough Council

Site or topic Main Issues DTC • CBC has worked closely with CCC including shared evidence base. Joint work will need to continue for delivery of infrastructure including A12 improvements and mainline railway capacity. • Insertion of elements of joint strategic plan within objectives, policies and allocations is welcome. Site allocations • Will have no strategic implications for Colchester growth

Appendix 1

Epping Forest District Council (EFDC)

Site or topic Main Issues Gypsy and Traveller • Supports Chelmsford aim to meet its own Gypsy and Traveller needs through the Plan. The final Essex-wide Gypsy and Traveller assessment may mean the matter will need to be revisited if the position changes. Policy S12 • Please keep EFDC informed on scoping of any new Park & Ride on A414 to ensure any impacts on A414 through EFDC’s area can be considered. HRA • Appropriate that the Epping Forest Special Area on Conservation is not referred to due to distance, ongoing work in West Essex/East Herts HMA will address cumulative impacts – continued engagement is encouraged.

Greater London Authority (GLA)

Site or topic Main Issues General • GLA population and household projections will be published w/c 10 July. • Would like a conversation with NE authorities and CCC (with egard to NE Chelmsford) about potential collaboration opportunities • Would like to understand CCC’s view on wider land requirements for freight/logistics, and relocation of industrial land • See also Transport for London comments on transport.

Maldon District Council (MDC)

Site or topic Main Issues Strategic Policy S12 • Need to ensure CCCs proposals do not impact on Maldon Infrastructure residents in relation to infrastructure requirements • A414, A132, B1012 corridors support economic ties with Chelmsford, need to ensure free movement - including for access to Beaulieu Park Station. Strategic Policy S15 • 1,900sqm allocation of convenience retail N of SWF, plus new role of centres Co-op and further 4,900sqm already granted could have a negative impact on Maldon convenience retail. Preference would be for no additional retail at SWF. Wish to discuss this impact further through DTC. Growth Area 1 • Development must be supported by congestion alleviation. Cross boundary travel, especially for business, should be as unimpeded as possible. Appendix 1

Strategic Growth • Would like to work together on masterplanning for sites, Sites 3a to 3c country park, P&R expansion, and impact on A414. 3c should be considered alongside MDC’s proposals for new / regenerated commercial areas. Strategic Growth Site • Concern if development includes the escarpment south of 8 Bushy Hill and any effect on open character. • Extensive landscaping expected to set a clear development limit, to avoid pressure for growth in Maldon district. • Would welcome involvement in masterplanning process. • Vital that infrastructure takes account of movement between the two districts. • Investigate improved capacity at these junctions: Shaw Farm, B10102/B1418, B1012/Hullbridge Road, B1012/Ferrers Road/Hamberts Road, B1012/Lower Burnham Road/Woodham Road • Wish to discuss with CCC and ECC a strategy and investment plan to alleviate congestion • Wish to work closely with CCC and ECC on implications for other infrastructure accessed by both districts • Seek reassurance that office and retail growth at SWF will not inhibit MDC’s employment and retail proposals Strategic Growth Site • Danbury allocation creates uncertainty for highway capacity on 10 the A414 – suggest this allocation is reconsidered. General / DTC • Discussions needed between all cross boundary bodies to ensure development proposals remain on course and housing trajectories are met. • Development at SWF must relate to context, environmentally sensitive areas, and open countryside. Proposals Map • Should extend area to include B1012/Woodham Road (to Cold Norton), and Rettendon Turnpike.

Rochford District Council (RDC)

Site or topic Main Issues Gren Belt • Without a Green Belt (GB) assessment, it is not clear how Strategic Policy S2 allocations in the GB would be inappropriate. Need to demonstrate that this promotes sustainable patterns of development. • Failing to consider higher tier settlements in GB could be detrimental to vitality of rural centres in long term. • Some GB locations such as previously developed land could be justified, and sustainable. Opportunities could be missed. • May not be appropriate to consider the Green Belt as an environmental designation per se. Appendix 1

Strategic Priority 2 • Welcomes approach, particularly in the light of potential for SE needs for new homes HMA authorities being unable to meet their need – both for housing & Gypsy and Traveller and Travelling Showpeople accommodation • South Essex HMA and Mid Essex HMA authorities should continue to work closely together. Strategic Priority S3 • Job growth is crucial to support commuters from other growth and authority areas. Assessment may be needed on the level of jobs investment to support housing outside upper tier settlements. Strategic Priority 5 • Important also to consider impact of growth on strategic strategic highways network outside CCC area, particularly to the south. infrastructure • Investigate rail line improvements as a sustainable option alongside highway improvements. • Improvements to A12/A130 junction are vital, to complement Fairglen improvements. Strategic Priority 9 • The draw of Chelmsford extends beyond the Mid Essex HMA, so CCC should assist other authorities in meeting their unmet need, based on robust evidence. Strategic Policy S6 • Encourage careful consideration of the A130 landscape natural environment corridor, to safeguard its rural setting. • Recommended to include specific references to houseboats and ‘liveaboards’ to manage impact on natural environment (Rochford DC have a policy). Approach by Maldon, CCC and RDC is not consistent. Suggest co-ordinated approach through DTC. Strategic Policy S8 • Possible that SE HMA will approach CCC to address unmet development Gypsy and Traveller and Travelling Showpeople accommodation requirements needs. Strategic Policy S12 • Concern about the potential impact on highways, especially A132, from development in Maldon and Chelmsford areas. • Railway line at SWF has significant potential for improvement – dual track line or passing points – would need evidence. Talks should start now. • RDC’s local plan includes aspiration for the national cycle network from Stock to Southend. DTC • SE HMA and ME HMA authorities should continue to work closely to meet housing needs of all authority areas.

Tendring District Council

Site or topic Main Issues General • Welcomes the timescale, inclusion of elements of NE authorities’ joint strategic plan, protection of the Green Belt, Strategic Policy S8, Site Allocations, Policy CO1

Appendix 1

Thurrock Borough Council

Site or topic Main Issues Strategic Policy S8 • Concern the Plan does not address potential unmet housing development need, particularly from South Essex and Thurrock. Needs to be requirements addressed under DTC. • Cross-boundary migration and commuting may have implications for unmet needs of South Essex. • May be a cumulative need from South Essex, partly from Thames Gateway growth. SE authorities are working on a Strategic Planning Framework, and updated SHMA. Some SE authorities are unable to meet OAN. Unmet need is a strategic matter. CCC plan should consider this further in preparing the Plan. • Wish to continue to engage on G&T and TS needs, including unmet need across boundaries.

Uttlesford District Council

Site or topic Main Issues General • Uttlesford DC wish to explore in more detail the infrastructure mitigation measures to support the level of development in the PO consultation and the potential impacts on the A120, in particular Junction 8 of the A120 and on surrounding villages. Judgement is reserved until further discussions through the DTC are explored.

Education Consultees

Anglia Ruskin University

Site or topic Main Issues S2 Sustainable • Commitment in strategic priorities and vision do not seem to be development (also taken forward into Strategic Policies. This risks weakening by S8, S15) omission, and could restrict future development opportunities for ARU. • Suggest that the need for growth in higher education facilities and associated uses is acknowledged alongside Chelmsford’s growth. • Suggest a University specific Strategic Policy (see Cambridge for example) to recognise the role and status, as with Writtle. This will enable Masterplanning for future growth. Text is then suggested for a policy S8 Development • Plan is virtually silent on the issue of student housing, although requirements the need is established in Housing Strategy Statement 2015-16. Appendix 1

• Add student housing to acceptable uses for site allocations, where appropriate. Happy to discuss/help to identify specific locations. Growth Site 1r, Ashby • Site in multiple freehold and leaseholds – uncertainty over House viability, speed, deliverability – suggest it’s deleted. Policy CA1 • Suggest a separate policy for new indoor and outdoor sports Community facilities facilities. Encourage provision of facilities for the local community, and facilities for meeting wider City needs including students – for well-being, health and societal benefits. • CA1 is too constrained and should set out support for sports facilities (as CA2 does).

Utility Consultees

Anglian Water Services (AWS)

Site or topic Main Issues Strategic Policy S8 • Reference should also be made to foul water treatment and Development disposal, including the need for phasing development where requirements appropriate. Strategic Policy S12 • Reference should be made to foul drainage as well as water Infrastructure supply. requirements Strategic Policy S13 • Support Securing infrastructure Policy CO1 • Concern about designation of Green Wedge – extension covers two sites owned by AWS including Chelmsford Water Recycling Centre. Must ensure planning designations are not overly restrictive. Green Wedge policy is a higher bar. Would seek removal of AWS landholdings from the Green Wedge. • GW policy says extension to north could provide formal and informal recreation, but AWS area is privately owned and so improvement or other use is undeliverable. • Sites 647 and 648 of Open Space Study are shown as natural green space, but are also in AWS ownership and let for agriculture, therefore not accessible – open space designation is unjustified and unsound. Policy CO3, RJ • Essential infrastructure is not limited to foul sewerage connections, and can include sewage treatment. Definition should change to refer to essential infrastructure more generally. Policy CO4 • Suggest changing wording, as it is unclear what basis the need for a rural location would be demonstrated Appendix 1

Policy CO6 and CO7 • These also seek to limit development in the Green Wedge, there may be a conflict with AWS future services and needs clarification. Policy S3 and NE3 • Working should be strengthened to ensure SuDs are utilised before considering discharging into public network, suggest wording change. Policy NE3 • Also make specific reference to foul water treatment and disposal, suggest wording change. Policy PA1 • Also consider potential amenity impacts of existing uses including sewage treatment, suggest wording change.

Essex & Suffolk Water (agent Savills)

Site or topic Main Issues Policy SPA3 • Supports the Special Policy Area (SPA) allocation. • Other operations on site include headquarters offices and ancillary functions. Suggest the policy is amended to reflect the whole site, rather than the water treatment works alone (add one word to policy). Proposals Map 33 • Open space shown in the SPA is part of the operational area, and not accessible to the public. It includes a lagoon which is sometime used for discharged water. There is good alternative access to open space meaning this need not be included. Suggested this is removed. • Safeguarding distance for hazardous substances has reduced to 450m and should be reflected on the Proposals Map (MP) (plan submitted for information).

Essex & Suffolk Water (agent Savills)

Site or topic Main Issues EC1 Land north of • Allocation is supported, planning application has been Galleywood submitted. Reservoir • Error in capacity figure in Table 10

National Grid (NG)

Site or topic Main Issues Site 8 SWF • Site is crossed by a NG high voltage electricity transmission overhead line – prefer no buildings direct beneath them, for occupiers’ amenity and for maintenance access. • Seeks to encourage high quality and well planned development, with land beneath lines being used to make a positive contribution – e.g. nature conservation, open space, parking. See A Sense of Place guidelines. Appendix 1

• NG policy is to retain overhead lines in situ – would only relocate to allow projects of national importance. • Links provided to further information – A Sense of Place, development near overhead lines, safe working, shape files

UK Power Networks

Site or topic Main Issues Electricity • Electricity infrastructure can accommodate much, if not all, infrastructure proposed development, provided homes continue to have gas heating. • Has been investment in north and east. • Capacity is reviewed annually and plans made for reinforcement where necessary. • Concern about increase demand from electric vehicle charging, as this may increase demand at peak times. New markets and technologies may be able to address this.

Environmental and Heritage Consultees

Environment Agency EA)

Site or topic Main Issues Strategic Priorities • Welcomes specifically SP 1; SP7; Para 3.17; Para 3.31. • Strategic Priority 5 could include reference future flood alleviation scheme for the City Centre including flood storage area and defence improvements. • Would welcome involvement in reviewing SFRA Level 2. • Support brownfield development, effects on environment should be minimal and seek mitigation for any impact. Para 3.30 • Add that the biodiversity and ecology benefits should also be protected; and identify the importance of water quality and protecting water quality against polluting surface water discharge to water courses. Vision • Support the vision but suggest additional emphasis: Seek to enhance ecology of features (river valleys & natural environment) and improve their water quality. Mention green and blue infrastructure for working towards vision of a low carbon future, maximising conservation value, river banks and waterways. Continue to protect the community from flooding/ improve flood risk. Spatial Principles • Environmental constraints such as flood risk not specifically mentioned. • Sustainable locations should also refer to protecting built development from flood risk. Appendix 1

• Developments should submit a Preliminary Risk Assessment (PRA) where contamination is known or suspected. Can affect water environment, and human health. Development offers a good way to deal with risks. Strategic Policy S3 • Suggest rephrasing of Para 2. Need a clear understanding of what we mean by safe & to what levels. What mitigation is acceptable, when should they be applied. Sequential siting and providing betterment. • Para 5.7 – add mention of increased river flows as well as rainfall. Strategic Policy S6 • Should include habitat quality and not just water quality – e.g. leading to policies to encourage new wetland areas to manage flood risk, alien species removal, de-culverting, removing redundant structures, planting in river corridor. Strategic Policy S12 • Strategic flood defence measures mentioned without any reasoned justification. Green infrastructure, water supply and waste water treatment infrastructure are also all mentioned in the policy but not discussed in the justification into where these areas should look to be improved. • Your local plan should look for specific local policy beyond the NPPF. Your further strategic work should consider here the local flood defence scheme. Policy GR1 • Explain what the appropriate flood mitigation measures are and when it is required. Strategic Growth Site 1a • Preliminary Risk Assessment (PRA) needed with any planning app. • Flood risk is a physical constraint (but design, type of development etc) can help to mitigate. • Define generous waterside margin – maintenance is 8m minimum, but an effective and valuable river corridor should be 20m. • Environmental Permit Regulations will need to be considered. • Any net loss of protected habitat not supported, but encourage betterment. • Ground floor non-residential is also a benefit for placing less vulnerable uses on the ground floor (from flooding perspective). • Explain in Reasoned Justification (RJ) what is meant by water storage areas, does Flood Alleviation Scheme (FAS) have a bearing, define safe refuge, what the appropriate flood mitigation measures are and what is required, evacuation routes, access, safe depths, hazard rating etc. Strategic Growth Site 1c • Will impact on the Green Wedge, take the opportunity to protect/enhance the natural environment. Appendix 1

• Suggest a 20m buffer from river bank for an effective and valuable river corridor. • Explain in RJ what is meant by water storage areas, does FAS have a bearing, define safe refuge, what the appropriate flood mitigation measures are and what is required, evacuation routes, access, safe depths, hazard rating etc. Strategic Growth Site 1g • Ground floor non-residential is also a benefit for placing less vulnerable uses on the ground floor (from flooding perspective). • Explain in RJ what is meant by water storage areas, does FAS have a bearing, define safe refuge, what the appropriate flood mitigation measures are and what is required, evacuation routes, access, safe depths, hazard rating etc. • E.g. no bedrooms at g/f level, g/f should ideally be raised above design flood level + CC, refuge should be provided on first floor, flood evacuation plan should accompany a FRA. Strategic Growth Site 1g • Does not mention the flood risk here – FZ 1, 2 & 3. Consider and reassess after Level 2 SFRA is conducted. Strategic Growth Site 3a, • Will impact on the Green Wedge, take the opportunity to 3b, 3c protect/enhance the natural environment. • Wish to be consulted on the masterplan. Strategic Growth Site 5 • Concern about Great Leighs allocation, in relation to wastewater treatment. Refer to Water Cycle Study (WCS). • Proposed allocation greatly exceeds earlier draft allocation in WCS and oversubscription in the area. Cannot agree that there are no overriding physical constraints. • Need to comply with Water Framework Directives, particularly phosphate levels. Asset management funding cycle (for WRC upgrade) may mean a 5-10 year delay. Strategic Growth Site 8 • Allocation of 1,000 homes can be supported; if allocation is higher, would like further discussions. Strategic Policy SPA5 • Agree that careful consideration is needed, happy to discuss details on protection to people and wildlife. Policy CO1, CO3, CO5 • Supported. Could also encourage development on new wetland habitats. • Objectives should contribute towards protecting and enhancing waterbodies, wildlife corridors, alien species removal, de-culverting, removing redundant structures, planting in river corridor. • Flood storage should be defined as functional floodplain/flood zone 3b in SFRA, as land that will be used to retain water during a flood for a 1:20 event. • CO5 Part B could define a small gap, and any mitigation to avoid negative impact on water quality, biodiversity & habitat. Appendix 1

Policy CO6 • RJ should also mention EA input into change of use in more vulnerable flood zones. Encourage betterment from existing flood risk to a higher level, including safe access/egress. Policy NE1 • Supported. Could add other water environment features to 8.101 such as removal of redundant structures and de- culverting where feasible. • Where protected species are likely, development must be surveyed and appropriate mitigation proposed. Policy NE3 • Welcome policy, but some additional work needed. Clarify what is meant by safe and how it can be achieved; development should look for betterment; safe access/egress or other management such as an evacuation plan; move Bii to C as it concerns SuDS and not fluvial matters. • Para 8.108, suggest a specific flood alleviation scheme policy, to address pre-scheme and post-scheme consideration for all new development. • Also suggest an Supplementary Planning Document (SPD) for future development with regard to flood risk and the FAS, to give advice to developers on their FRA (See Ipswich SPD). Policy MP3 • Supported, earlier comments have been incorporated. New dwellings should be sustainable for the lifetime of the development (e.g. 100 years for housing). Policy PA1 • Part ii could also include pollution to the water environment, which would also have an impact on amenity. Additional comment • Suggest a specific policy on protecting the water environment, and mention the Water Framework Directive and its objectives. Include an obligation to demonstrate a scheme does not cause a detriment in ground or surface water quality, surface water discharge in accordance with EA position statements. Proposals Maps • Would be easier to assess if they showed Flood Zone 2 and 3. They are a key constraint. • Potential odours to consider from waste centres at Winsford Way, Great Dunmow, skip site at Essex Regiment Way. More detail can be shared. Other • EA looking to develop flood risk standing advice about local specific risk issues, could form a / part of an SPD. • Suggest using EA guidance to help inform growth distribution, and application FRAs. Covers sea level rise, wave height, wind speed, peak river flow, rainfall intensity, etc. May help to inform fluvial maps and flood risk studies. • Level 2 SRFA advice, and potential future flood zone areas due to climate change, should inform site allocations. Appendix 1

• Further advice provided / resources to help provide clarity on what is meant by ‘safe’.

Historic England (HE)

Site or topic Main Issues General • HE has published various Good Practice Advice and Advice Notes which may help when developing the Plan • Welcome the inclusion of both a strategic policy for the historic environment as well as detailed policies and site specific polices. Further opportunity should be sought to address the historic environment in every aspect of the Plan and to make the strategy more spatially specific and unique to Chelmsford • Use the term historic environment rather than heritage assets throughout the Plan • Add a map of heritage assets Strategic Policy S5 • Welcome this strategic policy and other provisions in the Plan. Evidence Base • Expand to include other studies • Suggest a Topic Paper for the historic environment Chapter 2 About • Paragraph 2.29 – refer to the City’s 19 scheduled monuments, 6 Chelmsford historic parks and gardens, assets on the Heritage at Risk register and identify and describe local distinctiveness Strategic Priority 7 • Use the term historic environment • Expand reference to the historic environment in paragraph 3.27 Vision, Spatial • Use the term historic environment Principles and • Additional/expanded references to heritage are suggested to Strategic Policy S1 these sections Strategic Policy S1 Strategic Policy S12 • Include requirements to safeguard the grade II listed buildings/heritage assets that may be affected by new transport infrastructure e.g. the NE safeguarded route, new Park and Rides, Radial Distributor Road 2, A132 capacity improvements and Beaulieu Station Site allocations • Include references to protect and enhance heritage assets and policies the heritage environment and, the need for high quality design • Number bullet points Proposals Map • Show heritage assets including conservation areas, listed buildings • Make greater distinction between the site allocations and settlement boundaries Strategic Growth • Several allocations have heritage assets on or near to the site. Sites, Existing Many policies and reasoned justifications should ensure Commitments and additional/stronger references to conserving and/or enhancing Special Policy Areas heritage assets (Conservation Areas, Listed Buildings etc.) • SGS5, SGS4 and the site masterplan should include the need to protect/enhance heritage assets on or close to the site. Impacts on heritage assets need to be carefully evidenced and Appendix 1

considered given the amount of new growth proposed and the SA findings Policy HE1 • Welcome a separate policy for designated heritage assets Designated Heritage • Ensure policy complies fully with the NPPF Assets • Welcome provision for any future designation of conservation areas and specific provision for the landscape setting Policy HE2 Non- • Welcome a separate policy which accords with the NPPF designated Heritage • State that non-designated assets of archaeological interest are Assets considered under policy HE3 Heritage at Risk • Welcome a policy basis for the creation and management of a local Heritage at Risk register for Grade II listed buildings Policy NE4 • Include a specific policy relating to the inclusion of renewable Renewable and Low technologies within Conservation Areas and with regard to Carbon Energy historic buildings and the wider historic landscape Policy MP1 Design • Include requirement for consideration of the historic and Place Shaping environment within the design policies of the local plan Principles Policy MP6 Tall • Any assessment of key views and features should be referenced Buildings in the Plan or and assessment be undertaken Monitoring and • Welcome the historic environment indicators Implementation • Add completion of conservation area action plans and management plans and reduction in the number of assets that are classified as heritage at risk Glossary • Include several other terms including Listed Buildings, Scheduled Monuments and Conservation Areas Sustainability • References should be to the Historic Environment Appraisal • Several parts of the SA are welcomed/noted • The following sites should be appraised as having minor negative effects Navigation Road Sites, Essex Police HQ, Meteor Way, Former Chelmsford Electrical and Car Wash New St, Waterhouse Lane Depot and Nursery, Eastwood House and Rivermead Industrial Estate • Question what consideration is given to SPAs

Natural England

Site or topic Main Issues Strategic Priorities • Strategic Priority 7 should aspire to achieving net gain – as opposed to minimising effects on the environment. • Strategic Priority 8 recommendation to include ‘high quality green infrastructure’ • Plan for net-gains in nature as per paragraphs 109 and 157 in NPPF • Identify natural environment objectives, opportunities, areas for enhancement. Link to Biodiversity Action Plans, Local Nature Appendix 1

Partnerships, Rights of Way Improvement Plans, Green Infrastructure strategies. Strategic Policy S1 • Strengthen policy to include protection and enhancement. Strategic Policy S3 • Advise that a link is made between the role of green infrastructure in aiding climate change (paragraph 99 of the NPPF). • The garden communities NE Chelmsford (location 4) and Great Leighs (Location 5) should provide significant opportunities to aid climate change adaption. • Support the use of Sustainable Drainage Systems. Strategic Policy S6 • No information provided on strategic impacts on water quality and water resources, as well as effect of these on habitats • No policy statement included on light pollution – advise that policies address impacts on the natural environment. Strategic Policy S7 • The plan does not appear to consider impacts on soils • Recommend the inclusion of a specific Policy on soils, and Best and Most Versatile agricultural land. • Has site specific Agricultural Land Classification survey data been used to inform the scoring of SA Objective 7? • Needs higher aspirations towards net-gain in nature. Transpose into policies like Policy NE1 or Strategic Policy S6 Strategic Policies S10 • Welcome the principle, but do not recommend the policies & S11 include reference to brownfield land as ‘not of high environmental value’ Strategic Policy S12 • Advise timely delivery of improvements in relation to capacity issues at SWF Waste Water Treatment Works Strategic Policy S13 • Welcome addition of green infrastructure, advise policy is strengthened to ensure biodiversity and green infrastructure network creation and enhancement are included. Strategic Growth Site • Advise that the SA assessment include the River Ter SSSI 5 Strategic Growth Site • Whilst site has avoided Crouch and Roach Special Protection Area 8 and Ramsar site, concern with the proximity (~400m) and potential urbanising, recreational pressure and other impacts. Policy NE1 • Does not include a clear strategy for protecting and enhancing the natural environment. Policies should net-gain in biodiversity and be linked to local and national targets. • Policy should be reworded to demonstrate a further commitment. • Should include distinction between the hierarchy or international, national and locally designed sites. Policy NE2 • Recommend strengthening links between NE2 and S6 by including reference to protection of ancient woodland. Policy NE3 • Support all areas of this Policy. • Would recommend the role of natural flood management is considered. Policy NE4 • Reworded to include maximisation of delivery of green growth Appendix 1

Section 2 – About • Memorandum of Co-operation – CCC should work with Colchester Chelmsford and Tendering Councils regarding the Blackwater Estuary SPA and Ramsar sites and Basildon Council regarding the Crouch and Ramsar SPA and Ramsar site on strategic mitigation strategies. Other - Green • Advise that the Green Infrastructure Strategy is completed as a Infrastructure matter of urgency. • Advise that the provision of green infrastructure is included within a specific policy within the Local Plan or integrated into relevant other policies. • Advise that a minimum green infrastructure portion of 40% area be sought. Other – Recreational • Advise Council prepares strategic solution to identify measures to Pressure mitigate recreational pressures and include this in Local Plan Policies. Other – Air Quality • Advise neighbouring authorities to sign up to a Memorandum of Understanding to address impacts of Local Plans on Epping Forest with respect to air pollution. • Epping Forest SAC should be screened into the Habitats Regulations Assessment (HRA) process. • Based on the HRA concerns over scope, method and conclusions reached regarding air pollution effects on designated sites. • Where authorities are aware of plans/projects affecting the same road, these should be added up when calculating a threshold (1000 AADT change in traffic or 1% of critical load/level etc) • Concern that assessment of residual uncertainties for air quality on Crouch and Roach Estuaries SPA and Ramsar site does not take a sufficiently precautious approach – has not considered any plans other than SGS8, advise HRA re-visits habitats of the SPA that are sensitive to air quality. Other – Right of Way • Advise the benefits of Public Right of Ways is considered. Other – Habitats • Concerns over the scope, methodology, and some of the Regulations conclusions reached in the HRA report. Assessment Report • More detailed consideration is required to the protective measures that nearby sites may provide to protect European sites against disturbance and other impacts. • Disagree with the screen decision not to consider further the water quality aspects of the Essex Estuaries SAC and Crouch and Roach Estuaries. Other – Sustainability • Guide question under SA1 be amended to include ‘whilst Report protecting designated sites from the impact of increased recreational pressure?’ • SA framework should include a specific objective relating to enhancement of biodiversity, including green infrastructure. Other – Agricultural • Advise that council should include a specific policy on Soils and Land Best and Most Verstaile land; ensure clear decision making for lower quality agricultural land being used; strengthen the role of GI within development. Appendix 1

Marine Management Organisation (MMO)

Site or topic Main Issues General • Would alike additional references to the MMO, the Marine Policy Statement, and the emerging South East Marine Plan (not specified where in document). • Share a boundary at SWF on the River Crouch. • A number of links and resources quoted for marine licensing, marine planning and online guidance.

The Inland Waterways Association

Site or topic Main Issues Strategic Priority 6 • Pleased to see the Chelmer and Blackwater Navigation acknowledged in the Plan. However feel that its role as a 14 mile long ‘Country Park’ and recreational asset with tremendous potential is not recognised. • Similarly the potential of the City Centre rivers for sport, recreation and leisure use is also overlooked. Policy S1 • Should incorporate recreation and leisure use Strategic Growth Site 1a – • Pleased to see the continuing redevelopment of this area Chelmer Waterside • Disappointed that previous policies relating to the provision of The New Cut to link the Chelmer and Blackwater Navigation with the rivers in the City Centre no longer feature in the plan. • The public space requirement for the adjoining redevelopment should be located so as it can incorporate the link as and when funding sources are found. • The one time opportunity to at least protect the route of a ‘canal and river link’ must be incorporated in the Plan. • The link will provide essential additional water supply to Springfield Basin to allow its full operation – vital to the redevelopment of this area. • The new and improved pedestrian and cycle links should specifically include reference to the two bridges at the confluence of the Rivers Can and Chelmer – both need to provide greater width for pedestrians and cyclists and greater headroom for river users • The layout of the development is expected to ‘enhance the unique waterside location’ - should also include the wording ‘use’ to ensure opportunities to use the waterway are exploited.

Education and Skills Funding Agency (ESFA)

Appendix 1

Site or topic Main Issues Info • Established April 2017 for all state education funding. • Please add ESFA to Duty to Co-operate list – seeks close working • Please add ESFA to CIL and IDP consultation database. New schools • Commends CCCs approach to delivery of school places • Will be essential to define the need for places • Would be helpful to explicitly reference key national policies, e.g. NPPF para 72, Planning for Schools Development 2011 • Should also safeguard land for future expansion of schools where necessary • Next stage should demonstrate detailed forecast for school places and identify sites (existing or new). CIL contributions • Welcomes commitment to ensure contributions are sufficient, timely, phased, and forward funded where appropriate.

Royal Horticultural Society (RHS)

Site or topic Main Issues Strategic Policy SPA4 • Welcome the inclusion of a Special Policy Area – RHS Hyde Hall • Support principle of SPA Gardens Special • Boundary of SPA should be more widely drawn to reflect other Policy Area proposed schemes compatible with the role and function of Hyde Hall. Have provided alternative boundary suggestion • Ensures masterplan vision can be realised for the site in an effective manner. • Such schemes would not greatly compromise development or expand scale. Schemes could be against countryside policies but would be appropriate to reflect these in SPA. • Noted that areas outside designation are fit for horticultural/garden use, but to fulfil masterplan vision, encompassing area in the boundary would allow degree of flexibility • Inclusion of land within boundary will not prevent/alter need to assess appropriateness of developments

Transport Consultees

Highways England (HE)

Site or topic Main Issues Strategic Priorities 1, • Principles and approach is welcomed 5, 7 • Supportive of the new Local Plan. Vision • May be more appropriate to place greater emphasis on sustainable modes of transport – i.e. move ‘private transport’ to the end if the sentence. Appendix 1

Spatial Principles • Generally welcomed with following comments: • Garden community principles – many people work away from where they live, even where employment is provided nearby which may encourage in-commuting • Green Belt areas may have higher car dependency due to their rural nature Strategic Policies • S8, S9 Principles and approach is welcomed • S12 unclear from the Preferred Options what the funding sources are. Scheme delivery/non-delivery could impact on strategic road network, particularly J19 of A12 Site allocations • Do not state support or objection for allocations, but have listed some comments to be addressed. • The following should be clearly identified as needing to assess their impact on relevant strategic road network junctions as part of the transport assessment, in addition to those identified: o 1b (Essex Police HQ) o 1e (Gloucester Avenue) o 3c (South of Maldon Road) o 4 (NE Chelmsford) o 6 (N of Broomfield) o 7 (E of Boreham) o 8 (SWF) A12 corridor impact • The plan acknowledges to need to work together to proactively manage growth • Solutions being drawn up in response to HE consultation on A12 widening from Chelmsford to Colchester, further consultation in the autumn, with work expected to start in 2020 • Also developing options for M25 to Chelmsford o A12 Chelmsford bypass is heavily congested, intervention is likely to be needed: o J15 A414 – capacity improvement will be necessary as demand grows o J16 Temple Farm – Jehovah Witness print works development has low traffic generation. Junction operates well, despite heavy movement between Chelmsford and Basildon/Southend o J17 A130 – nearing capacity with peak time congestion, improvement will be necessary as demand grows o J18 Sandon - nearing capacity with peak time congestion. Concerns about impact from growth. Detailed traffic modelling will be needed. Third P&R may release some capacity at Sandon. o J19 Boreham – running at capacity and demand is increasing. HE is working with CCC/ECC and developer to combine and co-ordinate upgrades.

Transport for London Appendix 1

Site or topic Main Issues 2.25 • New trains on Liverpool Street to Shenfield from May 2017. Elizabeth Line (formerly Crossrail) fully open December 2019. S13 • Would welcome the opportunity to comment on the IDP • Principle of improvements to Great Eastern Mainline are support provided there are no adverse impacts on the Elizabeth Line. Enhanced rail from London to Norwich and also South-East is key part of Mayor’s transport strategy. • Road improvements in IDP need to consider impact on wider road network, with concern for any effect on London’s eastern corridor, i.e. A12, A13, A406 • Land use policies in PO need to minimise trip generation

Health Consultees

Mid Essex Hospital Services NHS Trust – Broomfield Hospital

Site or topic Main Issues Strategic Priorities • Seek confirmation that the Plan proposals have been informed by engagement with NHS England and Essex County Council • Helpful to understand how the City Council through the Plan could contribute to improving Broomfield hospital as the local acute hospital serving Chelmsford • Welcome the Plan objectives Strategic Growth Site 6 – • Welcome a second access route to the Broomfield Hospital North of Broomfield site. This needs to achieve appropriate traffic flow and routes and consider nearby land uses • Welcome improvements to the cycle and walking routes which should also link to the Hospital site Strategic Growth Site 4 - • Support the proposed transport improvements including NE Chelmsford on Essex Regiment Way, RDR2 and Beaulieu Park railway and proposals which improve access to the hospital site by public transport Strategic Policy S9 • Consider how public transport links can be provided from new housing developments to the Hospital site

Appendix 1

NHS England Midlands & East (East) (NHSE) and Mid Essex Clinical Commissioning Group (CCG)

Site or topic Main Issues General • Growth, in terms of housing and employment, would have an impact on future healthcare service provision. Existing GP practices in the area do not have the capacity to accommodate significant growth. • NHS England, Mid Essex CCG and CCC has begun to address capacity issues to meet current planned growth requirements to 2021 • Existing health infrastructure will require further investment and improvement in order to meet the needs of the planned growth shown in the LDP document. • Before further progression, CCC should have reference to the most up-to-date strategy documents from NHS England and CCG – The five year forward view and the emerging CCG Sustainability Transformation Plan. • There should be a policy included within the emerging LDP that indicates a supportive approach from CCC to the improvement, reconfiguration, extension or relocation of existing medical facilities. • NHS England and CCG will have significant comments to make as details of specific developments become available • Increase in the provision of assisted living and care homes, although a necessary feature of care provision and to be welcomed, can pose significant impacts on local primary care provision. Growth Area – Central • Mitigation - contribution towards increasing capacity for and Urban Chelmsford local Primary Care facilities through a number of projects, and South and East by means of reconfiguration, extension or possible Chelmsford relocation of one or more existing practices. In line with CCG Strategies. Growth Area – North • Mitigation - contribution towards increasing capacity for Chelmsford local Primary Care facilities through a number of projects, by means of reconfiguration, extension or possible relocation of one or more existing practices. In line with CCG Strategies. • A new build facility is planned in this area at Beaulieu Park, anticipated completion around late 2019 Strategic Site Policy • Mitigation required for potential new build in the area Reference 4, 5 & 6 Strategic Site Policy • Mitigation – contribution towards a potential new build Reference 8 facility for the area, to include one or more of the existing practices in South Woodham Ferrers.

Appendix 1

Sport Consultees

Sport England

Site or topic Main Issues Strategic Growth Site • Principle of redevelopment of playing field here would be 1c Meteor Way acceptable if adequate replacement provision was made. • However, the policy does not give clear enough guidance, to be consistent with the evidence base and NPPF. • Replacement in the form of financial contributions would be acceptable as like for like replacement may not be appropriate due to current limited use. Contribution should be equivalent to quantity and quality of pitch and ancillary facilities to mitigate the loss and provide certainly to developers on the level of contribution expected. • Policy should therefore cover both replacement playing field or financial contribution at appropriate cost, to avoid potential objections and delays at application stage. Happy to discuss. Strategic Priority 4, • Welcome the approach 6, 7, 8

Strategic Policy S12 • Welcome this, however some specific project references from the evidence base assessments to address community needs might be helpful, e.g. Riverside Ice & Leisure Policy GR1 • Specific reference should be made to providing contributions towards sports and leisure facilities. Size/nature of most urban sites will preclude on-site provision. Suggested wording given. Strategic Growth Site • Object to allocation of the sports ground. The Council’s 1b Essex Police HQ evidence base justifies the protection of the sports ground and specific proposals have been made in the Council's Playing Pitch and Outdoor Sports Strategy for meeting community needs if not required for its current use. Clear policy guidance is required on development affecting the sports ground in relation to protection or replacement which is consistent with both the Council's evidence base and Government policy in paragraph 74 of the NPPF. Strategic Growth Site • Object to the site allocation in relation to replacement playing 1d St Peter’s College field provision. • The policy should provide guidance on mitigating the impact of development on the playing fields – with flexibility to maintain the existing playing fields or replace them on-site. If financial contributions are secured in lieu of direct replacement, contributions should be at least equivalent to providing a replacement playing field. • If retained on-site, the policy should require enhancement of the playing field facilities and sustainable community use of it Appendix 1

(i.e. management/tenure proposals) to meet community needs and ensure long term sustainability. Strategic Growth Site • Object to the site allocation. The policy does not provide clear 1e John Shennan guidance on appropriate replacement provision. field • Evidence base has identified significant playing pitch deficiencies. The site would offer the potential for meeting community needs if brought back into use. • Any off-site replacement playing field provision should be equivalent or better in terms of quantity and quality and in a suitable location. If financial contributions are secured in lieu of direct replacement, contributions should be at least equivalent to providing a replacement playing field. • If retained on-site, the policy should require enhancement of the playing field facilities and sustainable community use of it (i.e. management/tenure proposals) to meet community needs and ensure long term sustainability. Potential for co-ordination with the dual use sports facilities provided on the adjoining Moulsham High School should also be explored. Strategic Growth Site • Policy guidance should specify provision of formal open 2 West Chelmsford space/outdoor sports facilities to meet future needs. If not provided on-site then financial contributions should be sought. • Evidence base has identified significant playing pitch deficiencies. Strategic Growth Site • Specific reference should be made to providing contributions 3a towards open space/outdoor sports facilities. Suggested Strategic Growth Site wording given. 3b • 3b should also address indoor facilities. East of Chelmsford Strategic Growth Site • Support for the policy. 4 North east • Also suggest including guidance that planning and design should Chelmsford be required to encourage healthy and active lifestyles (see Active Design Guidance) • http://www.sportengland.org/facilities-planning/planning-for- sport/planning-tools-and-guidance/active-design/ • Consider how a new secondary school can help to meet indoor sport/leisure needs through dual use facilities (such as new Beaulieu Park school). Strategic Growth Site • Support for the policy. 5 Moulsham Hall • Also suggest including guidance that planning and design should be required to encourage healthy and active lifestyles (see Active Design Guidance) Strategic Growth Site • Specific reference should be made to providing contributions 6 North of towards open space/outdoor sports facilities. Suggested Broomfield wording given. Strategic Growth Site • Specific reference should be made to providing contributions 8 South Woodham towards open space/outdoor sports facilities. Suggested Ferrers wording given. Appendix 1

• Also suggest including guidance that planning and design should be required to encourage healthy and active lifestyles (see Active Design Guidance) Policy CA1 Delivering • The RJ does not define the scope of community facilities, Community Facilities therefore open to interpretation. An indication should be given as a broad steer. E.g. open spaces can be seen as open space rather than community facilities when they are both, and commercial leisure facilities can be overlooked. • This should apply to new and enhanced facilities, to cover proposals for extending, refurbishing and replacing facilities. Policy CA2 Protecting • The RJ does not define the scope of community facilities, Community Facilities therefore open to interpretation. An indication should be given as a broad steer. E.g. open spaces can be seen as open space rather than community facilities when they are both, and commercial leisure facilities can be overlooked. • Criterion does not give adequate guidance for assessing proposals, as required by the NPPF Para 74. • Should include criterion for a surplus of provision, where benefits outweigh the loss, and alternative facility provision and its quantity/quality Policy MP1 – Design • Supporting text should refer to Active Design Guidance to and Place Shaping signpost applicants. Should also refer to the Essex Design Guide (under review – Sport England is actively involved)

Parish Councils within Chelmsford City Council’s Administrative Area

Boreham Parish Council

Site or topic Main Issues Map 7 Boreham Comments on the Defined Settlement Boundary as follows: • Support several minor changes to the boundary including inclusion of all of The Lion Inn • Object to proposed eastern boundary extension along Main Road. There is no planning reason or benefit to this

Broomfield Parish Council

Site or topic Main Issues Strategic Priority 1 • Does not set out clearly what sustainable principles the plan is looking to achieve. • Growth locations in North and West Chelmsford are not proven in the evidence base to be consistent with the principles of sustainable development Strategic Priority 5 • Concern about how the plan and proposals can be assessed in terms of robustness and delivery before the IDP has been developed. Appendix 1

• Strongly object as there is no certainty sites can be supported by infrastructure required. Particularly relevant for North Chelmsford in relation to the CNE Bypass – no certainty of this vital piece of infrastructure. • The plan should make clear how any necessary infrastructure be funded and any planned review of CIL Charging Schedule should be set out in the Plan. • Concerns about evidence provided by Ringway Jacobs (traffic modelling) Strategic Priority 7 • Insufficient evidence provided in the Plan to justify the permanent loss of grade 2 land Vision • The Plan seems to rely on a vision that has largely been achieved. A fresh, more aspirational vision is required. Plan should ask ‘What type of City does Chelmsford want to be’ • No evidence that village design statements, parish plans or emerging neighbourhood plans have been used to guide the development of the Plan. They provide sound evidence of aspirations of rural communities and should be reflected in the Plan. Spatial Principles – • Not clear why CCC has decided to adopt TCPA’s garden Garden Communities community principles • Should be further communication and consultation with local communities to discuss the process and outcomes • Definition should be provided on the difference between garden cities and garden communities • Plan should set out how CCC will pursue and intervene with this type of development, alongside developers and communities Spatial Principles – • Given Plans support for Garden Communities, it is unclear why Hammonds Farm Hammonds Farm could not be included (along with SGS 4), with a corresponding reduction in the number of urban/village extensions (SGS 2 and 6) Spatial Principles – • CCC dismissed a review of the green belt as part of the Plan Green Belt and Green process. Seen as a significantly missed opportunity. If not carried Wedges out now, perhaps won’t be for a further 2 decades. Unsatisfactory. Strongly support a green belt review being undertaken. • Landscape Sensitivity and Capacity Assessment should be further advanced to identify the merit of designations outside of the river valleys. • The extent to which landscapes are valued should take into account the value communities place upon them. Evidence base should take into account Parish Plans, Community Landscape Character Assessments, VDS. Spatial Principles - • Unclear how growth sites 2, 4 and 6 relate to existing Hierarchy developments or fulfil aspirations of policy objectives. Appendix 1

Strategic Policy S3 • Not clear why Warren Farm site is being taken forward when it is in the highest negative band for flood risk – strongly contravenes the objectives of the plan. • Appendix 7 states Warren Farm requires a Level 2 SFRA if the site is to be taken forward. This work should be undertaken before the next iteration of the plan to ensure the site is suitably deliverable. Strategic Policy S4 • The active Neighbourhood Plans in process should be given weight and consideration in the Plan. The Plan should therefore be amended to allow areas undertaking Neighbourhood Plans to allocate development sites for the required quantum of delivery though the Neighbourhood Plan process. Strategic Policy S5 • Historic environment not given enough consideration in some instances i.e. Warren Farm, the Chelmsford Centenary Circle Walk passes through Broomfield and Writtle. Strategic Policy S9 • Unclear why development should follow the settlement hierarchy set out in the Spatial Strategy Table. • No consistent definition of a Key Service Settlement. • Suggests that the distinction between Settlement Categories 2, 3 and 4 is removed and greater emphasis is placed on development in sustainable locations where infrastructure already exists. • North Chelmsford – no evidence that new growth can help deliver strategic infrastructure i.e. CNE Bypass • Seek further consideration of Hammonds Farm as a location for growth within the plan period Strategic Policy S12 • Considered premature to identify development locations based on potential improvements to transport infrastructure and an assumption as to the extent of model shift which can be achieved. • There is no evidence to support the assertion that people will not use their cars and will switch to buses or walk or cycle – highly likely people will choose to use their cars. • CNE Bypass essential piece of infrastructure • Disagree the aims and objectives of the County’s vision for Chelmsford’s transport system will be supported by the three growth areas • The modelling process utilised so far is inconclusive and does not appear to support the Preferred Option • A few minor measures (detailed) would help to improve traffic flow on the A130. Should be re-examination of number of roundabouts on Essex Regiment Way. Strategic Policy S14 • Do not wish to see the open landscape character of the rural parishes to the west of city destroyed by large scale urbanisation Site Allocation • Objects to the following policies GR 2,4,5,6, EC3 unless inclusion Policies of new primary school, SGS 2,4,5,6 • Strongly objects to locations 2 (Warren Farm), 4 (NE Chelmsford) and 6 (N Broomfield) Appendix 1

• SGS 2 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, loss of grade 2 agricultural land, impact on health services, impact on Chignal estate • SGS 4 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, flooding concerns, impact on health services and schools, impact on Little Waltham • EC3 before carried forward a robust costed achievable plan for building a school must be agreed • SPA1 much is supported, but last line relating to provision of new access road should be made conditional or removed Proposal Maps • Does not agree with proposal maps 1 & 8 • Also request that EC3 is removed from the Broomfield Defined Settlement Boundary as still subject to consultation Other Comments • Strongly supports the removal of Western Relief Road from Plan. However summary of responses is misleading – no options were favoured. • Request that Broomfield’s Parish Plan, VDS and Community Landscape Character Statement are added to the evidence base.

Chignal Parish Council

Site or topic Main Issues Strategic Priority 1 • Does not set out clearly what sustainable principles the plan is looking to achieve. • Growth locations in north and West Chelmsford are not proven in the evidence base • The Sustainability Appraisal Report assesses the sites in West Chelmsford as having a significant negative effect on landscape and waste and resources. These sites are therefore not delivering positive benefits and have significant impacts which go against the aspirations of the plan Strategic Priority 5 • Overall support for delivery of new infrastructure • Extraordinary that the IDP which will set out infrastructure is yet to be agreed. • Unclear how Plan and proposals can be assessed in terms of robustness and delivery • This is particularly relevant to North Chelmsford and specifically the CNE bypass. • Preferred Option should have taken greater account of newly improved infrastructure which is available to support growth e.g. A130 South and New Beaulieu Station • Unclear how current CIL Charging Schedule takes into account infrastructure investment required to service the new Local Plan. Review of Charging Schedule may be needed • Significant concerns as to the robustness of the evidence produced by Ringway Jacobs (traffic modelling). The evidence Appendix 1

base therefore requires further work to ascertain that the preferred option can be delivered in a sustainable manner Strategic Priority 6 • Concerns over uncertainty of delivery of key infrastructure i.e. CNE Bypass. On this basis object to the current preferred option Strategic Priority 7 • Insufficient evidence provided in the Local Plan to justify the permanent loss of Grade 2 land and there must remain suitable alternatives • Preferred Option is not the most sustainable and does not meet the Plans own aspirations. Vision • The Plan seems to rely on a vision that has largely been achieved. A fresh, more aspirational vision is required. Plan should ask ‘What type of City does Chelmsford want to be’ • No evidence that village design statements, parish plans or emerging neighbourhood plans have been used to guide the development of the Plan. The provide sound evidence of aspirations of rural communities and should be reflected in the Plan. Spatial Principles – • Not clear why CCC has decided to adopt TCPA’s garden Garden Communities community principles • Should be further communication and consultation with local communities to discuss the process and outcomes • Definition should be provided on the difference between garden cities and garden communities • Plan should set out how CCC will pursue and intervene with this type of development, alongside developers and communities Spatial Principles – • Given Plans support for Garden Communities, it is unclear why Hammonds Farm Hammonds Farm could not be included (along with SG site 4), with a corresponding reduction in the number of urban/village extensions (SG site 2 and 6) Spatial Principles – • CCC dismissed a review of the green belt as part of the Plan Green Belt and Green process. Seen as a significantly missed opportunity. If not carried Wedges out now, perhaps won’t be for a further 2 decades. Unsatisfactory. Strongly support a green belt review being undertaken. • Landscape Sensitivity and Capacity Assessment should be further advanced to identify the merit of designations outside of the river valleys. • The extent to which landscapes are values should take into account the value communities place upon them. Evidence base should take into account Parish Plans, Community Landscape Character Assessments, VDS. Spatial Principles - • Unclear how growth sites 2, 4 and 6 relate to existing Hierarchy developments or fulfil aspirations of policy objectives. Strategic Policy S3 • Not clear why Warren Farm site is being taken forward when it is in the highest negative band for flood risk – strongly contravenes the objectives of the plan. Appendix 1

• Appendix 7 states Warren Farm requires a Level 2 SFRA if the site is to be taken forward. This work should be undertaken before the next iteration of the plan to ensure the site is suitably deliverable. Strategic Policy S4 • The active Neighbourhood Plans in process should be given weight and consideration in the Plan. The Plan should therefore be amended to allow areas undertaking Neighbourhood Plans to allocate development sites for the required quantum of delivery though the Neighbourhood Plan process. Strategic Policy S5 • Historic environment not given enough consideration in some instances i.e. Warren Farm, the Chelmsford Centenary Circle Walk passes through Broomfield and Writtle. Strategic Policy S9 • Unclear why development should follow the settlement hierarchy set out in the Spatial Strategy Table. • No consistent definition of a Key Service Settlement. • Suggests that the distinction between Settlement Categories 2, 3 and 4 is removed and greater emphasis is placed on development in sustainable locations where infrastructure already exists. • Strategic Growth Sites are described misleadingly as ‘Central and Urban Chelmsford’ and ‘North Chelmsford’ when in fact all are located in rural parishes and do not represent true extensions to these settlements. • Similarly West Chelmsford, NE Chelmsford are rural locations • North Chelmsford – no evidence that new growth can help deliver strategic infrastructure I.e. CNE Bypass • Seek further consideration of Hammonds Farm as a location for growth within the plan period Strategic Policy S10 • Plan should seek to provide greater structure and certainty to ensure masterplans are produced and infrastructure forward funded to ensure sustainable and timely delivery. Strategic Policy S12 • Considered premature to identify development locations based on potential improvements to transport infrastructure and an assumption as to the extent of model shift which can be achieved. • There is no evidence to support the assertion that people will not use their cars and will switch to buses or walk or cycle – highly likely people will choose to use their cars. • CNE Bypass essential piece of infrastructure • Disagree the aims and objectives of the County’s vision for Chelmsford’s transport system will be supported by the three growth areas • The modelling process utilised so far is inconclusive and does not appear to support the Preferred Option • A few minor measures (detailed) would help to improve traffic flow on the A130. Should be re-examination of number of roundabouts on Essex Regiment Way. Appendix 1

Strategic Policy S13 • It is unclear how CCC can progress with options for growth without IDP which will give certainty of infrastructure required to deliver growth Strategic Policy S14 • Do not wish to see the open landscape character of the rural parishes to the west of city destroyed by large scale urbanisation Site Allocation • Objects to the following policies GR 2,4,5,6, EC3 unless inclusion Policies of new primary school, SGS 2,4,5,6 • Strongly objects to locations 2 (Warren Farm), 4 (NE Chelmsford) and 6 (N Broomfield). • SGS 2 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, loss of grade 2 agricultural land, impact on health services, impact on Chignal estate • SGS 4 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, flooding concerns, impact on health services and schools, impact on Little Waltham • EC3 before carried forward a robust costed achievable plan for building a school must be agreed. • SPA1 much is support, but last line relating to provision of new access road should be made conditional or removed Proposal Maps • Does not agree with proposal maps 1 & 8 – previous comments apply Other Comments • Strongly supports the removal of Western Relief Road from Plan. However summary of responses is misleading – no options were favoured. • Request that Broomfield’s Parish Plan, VDS and Community Landscape Character Statement are added to the evidence base

Danbury Parish Council

Site or topic Main Issues Growth Site 10 • Any development in Danbury should be allocated by the (Danbury) Neighbourhood Plan • Request clarification on recent permissions/developments and whether they would be included within the final number • Concern regarding cumulative impacts from growth in Maldon and Danbury e.g. on traffic and pollution • Concern that traffic flow projections are unrealistic – more detail requested. Proposals Map 10 • Extend Protected Lanes to include Gay Bowers Road (Danbury) (unprotected part), Hyde Lane (southern end), Twitty Fee, Woodhill Common Road, Herbage Park Road, Tyndales Lane and Slough Road • No objections to the Settlement Boundary Review. Alternative Sites • Very strongly objects to development at Hammonds Farm. Reasons include – in a flood plain and Landscape Conservation Area; adverse impacts on Danbury, Listed Buildings, traffic, Appendix 1

medical and educational provision; loss of valuable agricultural land and pollution • CCC urged not to allocate Hammonds Farm.

East Hanningfield Parish Council

Site or topic Main Issues Other comments • The expected increase in population must create a need for more family doctors, which should be quantified and provided for in the plan. Table 4 - Index to • East Hanningfield is already a rat-run for residents of South Growth Area 3 (SG Woodham Ferrers. Preventative measures need to be in place site 8) to dissuade new residents using local routes through the village which already experience congestion • There should be no access from SG site 8 on to Creephedge Lane. Strategic Growth Site • 7.183 should include Willow Grove/ Creephedge Lane 8 Proposals Map 11 • Do not accept rationale for including Rough Hill Complex in the Defined Settlement Boundary. If retained, also include the larger buildings, timber mill, finance company and learners’ swimming pool in the employment area • Agree that Land north of Old Church Road should be removed from within the settlement boundary.

Galleywood Parish Council

Site or topic Main Issues Existing Commitment • Development is too big and open space compensation is EC1 (Galleywood unclear – see also our comments to 16/01012/OUT Reservoir) • Table 11 should refer to 13 not 200 homes Proposals Map 14 • Request information on why changes have been made to the (Galleywood) settlement boundary • Employment Area should remain as employment (not for housing as indicated in the Galleywood VDS).

Great and Little Leighs Parish Council

Site or topic Main Issues Strategic Growth Site • Documentation is misleading and factually incorrect 5 (Moulsham Hall • Village has already had its fair share of new development. and North of Great Proposed quantum is disproportionate – distribute homes more Leighs) evenly between Parishes • Plan should treat Site 5 as three separate sites – (1) East of Main Road, (2) NE of Banters Lane and (3) West of A131 Moulsham Hall Appendix 1

• (1) East of Main Road. This would be an overdevelopment and decimate two Nature Reserves/ Ancient Woodlands. Nothing has changed since refusal of 100 houses. No provision for new school places. It is unacceptable to transport children to other primary schools • (2) NE of Banters Lane. Request answer as to where the Racecourse overflow would be situated if site is developed. Lack of facilities on site will increase travel to outlying areas. Cannot see how it would be possible to upgrade Main Road already impacted by vehicles from nearby businesses and the Quarry • (3) West of A131 Moulsham Hall. Reluctantly agree this site is the most viable option, but with reservations. Development should be a smaller scale, not occupy the whole site, include traffic mitigation and encourage foot and cycle paths routes. Infrastructure needs to be in place before the dwellings are built. Unclear why Travelling Show Persons plots are needed/viable. Concerned about adverse impacts including on noise, vehicle movements and property values • Chelmsford City Racecourse should be protected • Existing roads are already congested. New growth in Great Leighs and Great Notley will exacerbate this. Details on the delivery, funding and link roads from the NE Bypass are unclear • Focus new development close to existing trunk roads and railways stations e.g. Hammonds Farm and on more brownfield sites. Sustainability 1551AA16 – Land East of Banters Lane: Appraisal 155LAA28 CFS105 – Land East of Nos 170 – 194 Main Road PP33/34 – Moulsham Hall Site • SA indicates that these sites will have a negative on Great Leighs e.g. on traffic pollution, health services, schools and local distinctiveness which the Plan seeks to protect • Village does not have a supermarket Proposal Map 16 • Oppose inclusion of Banters Lane within the Defined Village (Great Leighs) Settlement (if SG5 comes forward) • No consultation has taken place with the Parish Council • Object to all the suggested changes • Changes would risk merging with Great Notley and do not follow the criteria.

Great Baddow Parish Council

Site or topic Main Issues Site 3a – Land north • Area polluted by leaching of chemical waste from waste tip on of Maldon Road – Baden Powell Close. Site not attractive to developers as would Appendix 1

Residential generate low profits, insufficient for contribution to CIL or Development building affordable housing. Site 3c – Land East of • Major gas pipeline lies under site (from Canvey Island to Molrams Lane Central Chelmsford). • Concern raised about power lines associated with substation close to proposed site. Site 3a and 3c - • Concern that size of two developments will not provide Infrastructure community facilities but in fact put strain on additional services (schools, doctors, shops, parking etc). • Concern that children living in new developments will be bussed to schools all around Chelmsford. • Pressure on Army and Navy and congestion around new access roads/junctions in Molrams Lane and Maldon Road – from cars and trucks – will be a result of this development. • At best, development will contribute to minimal improvements to Army and Navy. • Noted that there are no plans to improve A12 around Chelmsford, despite the road taking on more traffic from A130 and A414. • Have noted plans to improve A12 around Boreham interchange and Margaretting. Site 3a and 3c - • Residents’ called for substantial proportion of affordable Housing housing, 2-bedroom housing as opposed to larger houses. • Sizable minority of residents suggest petition to central government to grant the building of council housing, where affordable housing is beyond reach of the lower paid. • Support for modular housing to reduce costs. Green Wedges • Request decision to exclude area 3a from green wedge along River Chelmer to be reversed for the final proposal. • Want it recognised that area 3a is important contribution to green wedge, adds character to river valley and separates Great Baddow from the river and Chelmer Village. • Please consider The Chelmer and Blackwater Conservation Area Appraisal (2009) recommending that consideration be given to "extending the boundary of the Conservation Area to the A1114/A1060 to include agriculturally important valley sides." • Concern about removal of part of green wedge which helps mitigate pollution from Army and Navy.

Little Baddow Parish Council

Site or topic Main Issues General • General support for Vision, Spatial Principles and Spatial Strategy. Appendix 1

Strategic Priority 5 • Concerns that the detailed traffic modelling needs to be completed to establish the impact on the strategic highway network Vision • Support for Vision Spatial Principles • Support for Spatial Principles in particular the approach to the Settlement Hierarchy, general locations for development and the decision not allocate Hammonds farm for development Policy S8 • Support for decision to provide 20% buffer to OAHN Policy S9 • Concerns over adequacy of Boreham Interchange proposals Policy S13 • Strongly support objective to provide timely infrastructure Growth Site 10 • Concerns over impact of 100 homes on the existing severe Danbury congestion on the A414 particularly at Eves Corner. Suggestion that sites should be investigated to the west of Danbury Strategic Growth Site • No objection in principle concerning access to sites 7 Policy CO4 • Concerns over the way the new policy is framed with regard to harm to the intrinsic character and beauty of the countryside. Policy PA1 • Support for policies. No cross references within policies. Policy CO5 • Fails to recognise the differences in character and beauty of the rural area Policy C06 • Concerns about the time period required for an agricultural building to be in place before it can converted and there needs to be a cross reference to amenity policy PA1 Policy CO7 • Concerns raised about lack of cross references to amenity policy PA1 needed to car parking standards and lack or reference to the original size of the house. Policy HE2 • Not an adequate replacement to a specific Protected Lanes policy Proposals Map • Defined Settlement boundary for Little Baddow should be adjusted to take account of recent permission for new dwelling.

Little Waltham Parish Council

Site or topic Main Issues General • Concern that a disproportionate amount of development is planned in one area without adequate infrastructure • Focus growth in areas close to transport links e.g. east of the A12, Boreham area and Danbury area • Concerned about impacts of SG sites 4 and 6 and TS1 on the Parish e.g. traffic/congestion • CNE Bypass is not guaranteed and its delivery must be directly tied to SG sites 4,5 and 6 • Concern that the housing delivery rates are not realistic Strategic Priority 1 • Growth locations in north and West Chelmsford are not proven in the evidence base or consistent with the principles of sustainable development Appendix 1

• The Sustainability Appraisal Report assesses the sites in West Chelmsford as having a significant negative effect on landscape and waste and resources Strategic Priority 5 • Concern about how the plan and proposals can be selected and assessed in terms of robustness and delivery before the IDP has been developed. • Strongly object as there is no certainty sites can be supported by infrastructure required. Particularly relevant for North Chelmsford in relation to the CNE Bypass – no certainty of this vital piece of infrastructure. • The plan should make clear how any necessary infrastructure will be funded and any planned review of CIL Charging Schedule should be set out in the Plan. • Concerns about evidence provided by Ringway Jacobs (traffic modelling). Broomfield, Chignal, Little Waltham and Writtle Parish Councils have commissioned their own transport consultant to review the traffic modelling – a copy is attached to the submission. Strategic Priority 6 • Plan does not provide robust proposals or certainty about new healthcare provision Strategic Priority 7 • Insufficient evidence provided in the Plan to justify the permanent loss of grade 2 land Vision • The Plan seems to rely on a vision that has largely been achieved. A fresh, more aspirational vision is required. Plan should ask ‘What type of City does Chelmsford want to be’ • Vision should have greater emphasis on sustainable communities, quality of life issues and on new settlements • No evidence that village design statements, parish plans or emerging neighbourhood plans have been used to guide the development of the Plan. The provide sound evidence of aspirations of rural communities and should be reflected in the Plan Spatial Principles – • Not clear why CCC has decided to adopt TCPA’s garden Garden Communities community principles, how this will happen and why Hammonds Farm is not a Preferred Option Spatial Principles – • CCC dismissed a review of the green belt as part of the Plan Green Belt process. Seen as a significantly missed opportunity. If not carried out now, perhaps won’t be for a further 2 decades. Unsatisfactory. Strongly support a green belt review being undertaken • The NPPF makes provision for a review needed to cover the new Plan period. Spatial Principles – • This principle is too narrowly defined Valued Landscapes • Consider Green Wedge designation for other strategic tracks of landscape quality threatened by development e.g. area between Broomfield and Little Waltham Appendix 1

• Landscape value should be informed by the value placed on them by surrounding communities Spatial Principles – • SG sites 2, 4 and 6 are not connected to existing centres of Settlement Hierarchy population and community services. These developments could create urban sprawl and ribbon development along Essex Regiment Way Spatial Principles – • Relying on developers to deliver necessary infrastructure can Infrastructure mean it is not supplied when first needed Strategic Policy S4 • Parishes without resources to develop Neighbourhood Plans should not be disadvantaged Strategic Policy S9 • Strategic Growth Sites in Growth Areas 1 and 2 are misleadingly described and as ‘Central and Urban Chelmsford’ when in fact all are located within rural parishes • Unsustainable and unfair for Little Waltham Parish to accommodate 19 pitches for Travellers • Extremely optimistic that residents of SG sites 4 and 6 will walk into Chelmsford • Developments in NE Chelmsford phased in first five years are unlikely to deliver the required infrastructure until the end of the Plan period • Seek further consideration for rejection of Hammonds Farm as a location for growth within the plan period Strategic Policy S10 • Request information on assurances masterplans will be produced and infrastructure forward funded for the greenfield sites Strategic Policy S12 • The Sustainability Review (traffic modelling) does not provide an accurate review of the quality or reliability of the bus services available • Potential improvements to improve bus services are not deliverable in reality due to conditions on the ground • Considered premature to identify development locations without assurances that improvements to transport infrastructure can be made and delivered • Question what evidence is available to support the assertion that people will switch from their cars to buses or walk or cycle – highly likely people will choose to still use their cars • Disagree the aims and objectives of the County’s vision for Chelmsford’s transport system will be supported by the three growth areas • Concerns regarding the quality and scope of the modelling work which does not appear to support the Preferred Option • The Plan relies on potentially undeliverable infrastructure improvements that would need to be assessed and evaluated prior to such an option being promoted. Strategic Policy S13 • The IDP should have informed the Preferred Options Appendix 1

• There is no indication that funding will be forthcoming for key transport improvements such as the cNE Bypass • Reliance on developer led infrastructure is flawed Strategic Policy S14 • SG sites 4 and 6 are at odds with this policy • Do not wish to see the open landscape character of this rural parish destroyed by large scale urbanisation Site Allocation • Agrees with GR 1a – s, 3a, b, c; 7; 8; 9; 10; OS1a-c; EC1; EC4; Policies – Warren CW1a-f; SGS1a-g; GS1h-s; SGS 3a,b,c; 7; 8; 9; 10 Farm • Objects to policies site 2,4,5,6, EC2, SGS2,4,5 and 6 • SG sites 2, 4 and 6 are not sustainable and do not comply with the Plan • SG site 4 is not sustainable for reasons including an increased traffic congestion, lack of footpaths/cycle way connections, landscape sensitivity, mineral safeguarding, flooding concerns, impact of Little Waltham village and impact on health services and schools. • SG site 6 is not sustainable for reasons including loss of the gap between Chelmsford and Little Waltham village, it would result in urban sprawl, adverse landscape impacts and traffic impacts in Little Waltham village. There has been no testing of the benefits of the new access road Proposals Map • Do not agree with maps 1 and 8 – see previous comments to sites 2, 4 and 8.

Runwell Parish Council

Site or topic Main Issues Strategic Policy 1 – • Several small building developments have been given Protect the Green permission within the Green Belt which is inconsistent with Belt policy. This is confusing and inconsistent. Proposals Map • Support the proposed changes to Runwell Defined Settlement Boundary and potential boundary for St. Luke’s Park. Strategic Growth Site • Greater emphasis and financial commitments is needed on 8 improving the train service to Wickford Main Line Station as many commuters use the A132 as the train service is poor • Car parking facilities will be needed at Wickford Station Transportation • Broomfield Hospital will be the main Accident and Emergency Centre with a change of emphasis at Basildon and Southend. Transport links to this area must be prioritised.

Sandon Parish Council

Site or topic Main Issues Strategic Policy S9 – • Plan does not provide any options. Hammonds Farm is far Spatial Strategy better than SG sites 3a,b or c Appendix 1

• Concern that could get 3a-c and Hammonds Farm, which would be a disaster. Strategic Growth • Object to SG sites 3a-3c for reasons including loss of agricultural Sites 3a-3b land, beautiful views, sufficient brownfield sites are available, flood risk and traffic impacts on the local network which is already at full stretch • Site 3a also has contaminated land, would harm the local landscape and should provide a new school. The development is not justified by providing a Country Park • Site 3b. Other concerns include whether there is a need for this type of employment and adverse impacts on the Park & Ride • Site 3c. Other concerns include pylons, heritage assets, destruction of woodland along Maldon Road, sewerage flooding, major gas pipeline and Sandon being swallowed up by Great Baddow • The site allocation policies lack detail on how requirements in the policy will be delivered • If the developments go ahead, infrastructure should be built first including the Park & Ride extension • Residents at the Annual Assembly on Tuesday 25th April 2017 gave a resounding no to all the proposals in 3a, 3b and 3c.

Springfield Parish Council

Site or topic Main Issues Strategic Growth Site • Include health care provision within the proposed 4 neighbourhood centre • Funding for the proposed new road infrastructure must be secured prior to any planning consent for new homes Strategic Policy 12 • Wish to see improvements to the A12 including three lanes.

South Woodham Ferrers (SWF) Town Council

Site or topic Main Issues Strategic Growth Site • Concerned that existing infrastructure will not be enhanced or 8 (North of SWF) improved sufficiently to support and accommodate the additional growth including sustainable transport, crossing over the B1012, rail capacity, flood defences and improvements to the A132 corridor • Evidence base is too Chelmsford focused and lacking in support of SGS8 • No evidence that infrastructure developments have been fully considered. New growth will put more pressure on facilities within the town which will be unsustainable • Unclear if new retail provision will be required if Sainsbury’s is built. Two supermarkets in SWF may degrade services and detract investment from the current Town Centre Appendix 1

• Additional on-site retail provision would be isolated from the rest of the town • No evidence if plan considers the impacts of other new growth on SWF e.g. in Maldon and Basildon, particularly on local roads • No evidence that development will deliver the three strands of sustainable development in the NPPF • Concern proposals will not integrate with existing town • Proposals for SUDs and for addressing climate change are too limited. Car clubs are not a planning service • Many of the policy requirements are not justified and/or lack detail e.g. need for new primary school, community facilities, new cycle and footpath routes and crossings and capacity improvements along the A132 • If justification for 1000 homes is made, the Travelling Showpersons site is acceptable. It should not be able to expand and policed effectively when show people are on the road Vision • 70% agree and 30% disagree with the vision in respect of SWF • No evidence that SGS8 will continue the “revitalisation of South Woodham Ferrers Town Centre, by enhancing its retail, cultural and leisure offer” Strategic Priorities • SP1-5 have not been met in respect of SGS8 • SP6-7 have been partially met in respect of SGS8 but no evidence is given Spatial Principles • 20% agree and 80% disagree with the SPs in respect of SWF (Policy S1) • Most are either not applicable to SGS8 or SWF Town or no/limited evidence has been provided to show how the SP will be met • SGS8 should help to preserve the gap between SWF and Woodham Ferrers which is supported Strategic Policies • Most are either not applicable to SGS8 or SWF Town or there is no/limited evidence to show how the SP will be met • S4 - Proposals for addressing climate change e.g. car clubs are too limited • S8 – Quantum of new housing and business floorspace for Strategic Growth Site 8 is not justified. Request an HMA is formed with SWF and LPAs in south Essex and that a separate OAHN study conducted. New jobs creation will be limited and no evidence jobs will go to new residents • S9 – No evidence to support SWF’s position in the Settlement Hierarchy or that Site 8 can be a sustainable development • S12 – commuting from SWF has not been considered. Beaulieu Station could adversely impact rail services offered at SWF which could not cope with extra passengers generated from SGS8. A new terminal or passing platform will be required • S13 – IDP must be robust Appendix 1

• S14 – Consider if a green buffer is needed adjacent to Maldon District and around Fen Creek Special Policy Area 4 • No evidence for the Special Policy Area – RHS Hyde Hall Gardens

Woodham Ferrers and Bicknacre

Site or topic Main Issues Housing Needs • Affordable housing is a priority for Bicknacre and have referred to their results from Housing Surveys conducted in 2008 and 2012 to support their claim. • For the Bicknacre area, more 2/3 bedroom houses are needed for older generations of residents who wish to downsize but remain in the area • Please consider building low level apartments/flats as these would supply more accommodation per square foot and can work as affordable housing.

Writtle Parish Council

Site or topic Main Issues Strategic Priority 1 • Does not set out clearly what sustainable principles the plan is looking to achieve. • Growth locations in north and West Chelmsford are not proven in the evidence base • The Sustainability Appraisal Report assesses the sites in West Chelmsford as having a significant negative effect on landscape and waste and resources. Strategic Priority 5 • Overall support for delivery of new infrastructure • Extraordinary that the IDP which will set out infrastructure is yet to be agreed. • Unclear how Plan and proposals can be assessed in terms of robustness and delivery • This is particularly relevant to North Chelmsford and specifically the CNE bypass. • Preferred Option should have taken greater account of newly improved infrastructure which is available to support growth e.g. A130 South and New Beaulieu Station • Unclear how current CIL Charging Schedule takes into account infrastructure investment required to service new Local Plan. Review of Charging Schedule may be needed • Significant concerns as to the robustness of the evidence produced by Ringway Jacobs (traffic modelling). The evidence base therefore requires further work to ascertain that the preferred option can be delivered in a sustainable manner Appendix 1

Strategic Priority 7 • Insufficient evidence provided in the Local Plan to justify the permanent loss of Grade 2 land in growth locations in the west and north and there must remain suitable alternatives • Preferred Option is not the most sustainable and does not meet the Plans own strategic objectives. Vision • The Plan seems to rely on a vision that has largely been achieved. A fresh, more aspirational vision is required. Plan should ask ‘What type of City does Chelmsford want to be’ • Vision should have greater emphasis on sustainable communities, quality of life issues and on new settlements • No evidence that village design statements, parish plans or emerging neighbourhood plans have been used to guide the development of the Plan. The provide sound evidence of aspirations of rural communities and should be reflected in the Plan • Focus housing within walking and cycling distance of the new station to re-invigorate sustainable transport Spatial Principles – • Not clear why CCC has decided to adopt TCPA’s garden Garden Communities community principles when only SGS4 appears large enough • Should be further communication and consultation with local communities to discuss the process and outcomes • Definition should be provided on the difference between garden cities and garden communities • Plan should set out how CCC will pursue and intervene with this type of development, alongside developers and communities Spatial Principles – • Given Plans support for Garden Communities, it is unclear why Hammonds Farm Hammonds Farm could not be included (along with SG site 4), with a corresponding reduction in the number of urban/village extensions (SG site 2 and 6) Spatial Principles – • CCC dismissed a review of the green belt as part of the Plan Green Belt process. Seen as a significantly missed opportunity. If not carried out now, perhaps won’t be for a further 2 decades. Unsatisfactory. Strongly support a green belt review being undertaken • The NPPF makes provision for a review needed to cover the new Plan period. Spatial Principles – • SG site 2 is not connected to existing communities and services in Settlement Hierarchy Writtle or west and north Chelmsford Strategic Policy S3 • Warren Farm site has the highest negative band for flood risk – which detracts significantly from the achievement of sustainable development. • Appendix 7 states Warren Farm requires a Level 2 SFRA if the site is to be taken forward Strategic Policy S4 • The Plan should be amended to allow areas undertaking Neighbourhood Plans to allocate development sites for the required quantum of delivery though the Neighbourhood Plan process Appendix 1

Strategic Policy S5 • The Chelmsford Centenary Circle Walk runs through SG site 2. This section of rural landscape would be destroyed if developed Strategic Policy S9 • Unclear why development should follow the settlement hierarchy set out in the Spatial Strategy Table. • Remove distinction between categories 2, 3 and 4 and focus development in sustainable locations where infrastructure already exists or is forthcoming • Strategic Growth Site 2 is described misleadingly as ‘Central and Urban Chelmsford’ when in fact is located in Writtle rural parish • Seek further consideration of Hammonds Farm as a location for growth within the plan period Strategic Policy S10 • Request information on assurances masterplans will be produced and infrastructure forward funded for the greenfield sites Strategic Policy S12 • The Sustainability Review (traffic modelling) does not provide an accurate review of the quality or reliability of the bus services available • Potential improvements to improve bus services are not deliverable in reality due to conditions on the ground. Considered premature to identify development locations based on potential improvements to transport infrastructure and assumptions on the achievement of model shift • There is no evidence to support the assertion that people will not use their cars and will switch to buses or walk or cycle – highly likely people will choose to use their cars. • Welcome removal of NW Potential Relief Road • CNE Bypass essential piece of infrastructure – focus resources for transport infrastructure improvements on building it • Disagree the aims and objectives of the County’s vision for Chelmsford’s transport system will be supported by the three growth areas • Concerns regarding the quality and scope of the modelling work e.g. the impact of Widford Park and Ride has not been considered and a 5% reduction in traffic will not be achieved • The modelling process does not appear to support the Preferred Option • The Plan relies on potentially undeliverable infrastructure improvements that would need to be assessed and evaluated prior to such an option being promoted. Strategic Policy S13 • The IDP should have informed the Preferred Options • There is no indication that funding will be forthcoming for key transport improvements such as the CNE Bypass Strategic Policy S14 • Do not wish to see the open landscape character of the rural parishes to the west of city destroyed by large scale urbanisation Site Allocation • Agrees with GR 1a – s, 3a, b, c; 7; 8; 9; 10; OS1a-c; EC1; EC4; Policies – Warren CW1a-f; SGS1a-g; GS1h-s; SGS 3a,b,c; 7; 8; 9; 10 Farm Appendix 1

• Strongly objects to policies site 2 (Warren Farm) and site 4 (NE Chelmsford) Site 2 Objections based on: • This is not a sustainable location and development and there are other deliverable sites which could provide 800 homes • Development could urbanise the parish of Writtle • The negative factors of development here (e.g. on the economy, health and wellbeing, transport network, land use and water) far outweigh any positive benefits • Local and strategic roads are at capacity at peak times now and could not cope with the additional development. Road capacity improvements cannot be achieved • Landscape impacts could not be effectively mitigated without significantly changing the intrinsic character of the landscape in this location • No evidence to sustain a new school on the site • Flood risks are too great and the development will exacerbate the risk of flooding locally. Site Allocation • Quantum and density is too high given proximity to heritage Policies – Telephone assets and neighbouring uses. Also concerned about access and Exchange traffic conflicts and congestion Proposal Maps • Does not agree with proposal maps 1 & 35

Broomfield Parish Council, Chignal Parish Council, Little Waltham Parish Council, Writtle Parish Council and Newlands Spring Residents Association (‘the Councils’)

Site or topic Main Issues Strategic Priority 1 • Does not set out clearly what sustainable principles the plan is looking to achieve. • Growth locations in North and West Chelmsford are not proven in the evidence base • The Sustainability Appraisal Report assesses the sites in West Chelmsford as having a significant negative effect on landscape and waste and resources. These sites are therefore not delivering positive benefits and have significant impacts which go against the aspirations of the plan Strategic Priority 5 • Overall support for delivery of new infrastructure • Extraordinary that the IDP which will set out infrastructure is yet to be agreed. • Unclear how Plan and proposals can be assessed in terms of robustness and delivery • This is particularly relevant to North Chelmsford and specifically the CNE bypass. Appendix 1

• Preferred Option should have taken greater account of newly improved infrastructure which is available to support growth e.g. A130 South and New Beaulieu Station • Unclear how current CIL Charging Schedule takes into account infrastructure investment required to service new Local Plan. Review of Charging Schedule may be needed • Significant concerns as to the robustness of the evidence produced by Ringway Jacobs. The evidence base therefore requires further work to ascertain that the preferred option can be delivered in a sustainable manner Strategic Priority 6 • Concerns over uncertainty of delivery of key infrastructure i.e. CNE Bypass. On this basis object to the current preferred option Strategic Priority 7 • Insufficient evidence provided in the Local Plan to justify the permanent loss of Grade 2 land and there must remain suitable alternatives • Preferred Option is not the most sustainable and does not meet the Plans own aspirations. Vision • The Plan seems to rely on a vision that has largely been achieved. A fresh, more aspirational vision is required. Plan should ask ‘What type of City does Chelmsford want to be’ • No evidence that village design statements, parish plans or emerging neighbourhood plans have been used to guide the development of the Plan. They provide sound evidence of aspirations of rural communities and should be reflected in the Plan. Spatial Principles – • Not clear why CCC has decided to adopt TCPA’s garden Garden Communities community principles • Should be further communication and consultation with local communities to discuss the process and outcomes • Definition should be provided on the difference between garden cities and garden communities • Plan should set out how CCC will pursue and intervene with this type of development, alongside developers and communities Spatial Principles – • Given Plans support for Garden Communities, it is unclear Hammonds Farm why Hammonds Farm could not be included (along with SG site 4), with a corresponding reduction in the number of urban/village extensions (SG site 2 and 6) Spatial Principles – Green • CCC dismissed a review of the green belt as part of the Belt and Green Wedges Plan process. Seen as a significantly missed opportunity. If not carried out now, perhaps won’t be for a further 2 decades. Unsatisfactory. Strongly support a green belt review being undertaken. Appendix 1

• Landscape Sensitivity and Capacity Assessment should be further advanced to identify the merit of designations outside of the river valleys. • The extent to which landscapes are values should take into account the value communities place upon them. Evidence base should take into account Parish Plans, Community Landscape Character Assessments, VDS. Spatial Principles - • Unclear how growth sites 2, 4 and 6 relate to existing Hierarchy developments or fulfil aspirations of policy objectives. Strategic Policy S3 • Not clear why Warren Farm site is being taken forward when it is in the highest negative band for flood risk – strongly contravenes the objectives of the plan. • Appendix 7 states Warren Farm requires a Level 2 SFRA if the site is to be taken forward. This work should be undertaken before the next iteration of the plan to ensure the site is suitably deliverable. Strategic Policy S4 • The active Neighbourhood Plans in process should be given weight and consideration in the Plan. The Plan should therefore be amended to allow areas undertaking Neighbourhood Plans to allocate development sites for the required quantum of delivery though the Neighbourhood Plan process. Strategic Policy S5 • Historic environment not given enough consideration in some instances i.e. Warren Farm, the Chelmsford Centenary Circle Walk passes through Broomfield and Writtle. Strategic Policy S9 • Unclear why development should follow the settlement hierarchy set out in the Spatial Strategy Table. • No consistent definition of a Key Service Settlement. • Suggests that the distinction between Settlement Categories 2, 3 and 4 is removed and greater emphasis is placed on development in sustainable locations where infrastructure already exists. • Strategic Growth Sites are described misleadingly as ‘Central and Urban Chelmsford’ and ‘North Chelmsford’ when in fact all are located in rural parishes and do not represent true extensions to these settlements. • Similarly West Chelmsford, NE Chelmsford are rural locations • North Chelmsford – no evidence that new growth can help deliver strategic infrastructure i.e. CNE Bypass • Seek further consideration of Hammonds Farm as a location for growth within the plan period Strategic Policy S10 • Plan should seek to provide greater structure and certainty to ensure masterplans are produced and infrastructure forward funded to ensure sustainable and timely delivery. Appendix 1

Strategic Policy S12 • Considered premature to identify development locations based on potential improvements to transport infrastructure and an assumption as to the extent of model shift which can be achieved. • There is no evidence to support the assertion that people will not use their cars and will switch to buses or walk or cycle – highly likely people will choose to use their cars. • CNE Bypass essential piece of infrastructure • Disagree the aims and objectives of the County’s vision for Chelmsford’s transport system will be supported by the three growth areas • The modelling process utilised so far is inconclusive and does not appear to support the Preferred Option Strategic Policy S13 • It is unclear how CCC can progress with options for growth without IDP which will give certainty of infrastructure required to deliver growth Strategic Policy S14 • Do not wish to see the open landscape character of the rural parishes to the west of city destroyed by large scale urbanisation Site Allocation Policies • Objects to the following policies GR 2,4,5,6, EC2, EC3 unless inclusion of new primary school can be guaranteed, SGS 2,4,5,6 • Strongly objects to locations 2 (Warren Farm), 4 (NE Chelmsford) and 6 (N Broomfield). • SGS 2 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, loss of grade 2 agricultural land, impact on health services, impact on Chignal estate • SGS 4 objection based on increased traffic, no cycle/walking connections, landscape sensitivity, flooding concerns, impact on health services and schools, impact on Little Waltham • SGS 6 objection based on traffic generation, highway safety considerations, impact to the character of the existing settlement, poor cycle and pedestrian paths, concern that one form entry primary school would not be viable longer term • EC3 before carried forward a robust costed achievable plan for building a school must be agreed. • SPA1 much is supported, but last line relating to provision of new access road should be made conditional or removed Proposal Maps • Does not agree with proposal maps 1 & 8 – previous comments apply Other Comments • Strongly supports the removal of Western Relief Road from Plan. However summary of responses is misleading – no options were favoured. Appendix 1

• Request that Broomfield’s Parish Plan, VDS and Community Landscape Character Statement are added to the evidence base

Adjoining Parish Councils

Black Notley Parish Council

Site or topic Main Issues Strategic Growth Site • Strongly oppose development plans, endorse their previous 5 – Moulsham Hall comments put forward at the Chelmsford Draft Plan. and North of Great • The plan allocates a disproportionate amount of housing to Leighs Great Leighs. • Great Leighs already has an overburdened road system, development will put hundreds of additional cars on Bakers Lane on a daily basis. • There are already plans for 2000 houses to be in the Parish of Black Notley. Additional development in Great Leighs will put stress on schools and shops (such as Notley High School and Freeport). • Consider allocating students school places in Chelmsford as Bakers Lane leading to Notley High School is already an “overburdened rat-run”. • Bakers Lane is the only route to industrial estates Duggers Lane and Skitts Hill, is a back route to the A12 and has listed buildings located close to the road. Additional school traffic would create a dangerous situation for pedestrians, and inconvenience for residents. • Suggest addressing road infrastructure before building houses. Perhaps create a link road from Notley road to London Road to alleviate the issue. • Perhaps consider Broomfield as they need key workers and is cycling distance from Chelmsford City Centre.

Great Notley Parish Council

Site or topic Main Issues Strategic Growth Site • Do not object to development in principle but concerned 5 – Moulsham Hall regarding impact to services and infrastructure within Parish of and North of Great Great Notley. Leighs • Note there are proposals to build new schools and facilities (shops, medical services etc) but such services should be provided as development progresses to avoid excessive strain on existing services. • Concern that existing road networks will come under strain. Aware of proposal for North East bypass but this would not Appendix 1

relieve traffic into Braintree District leading to congestion around Great Notley Parish. • Suggest consideration to how/when road network is developed to prevent congestion from new development. Policy SPA2 • Noted that City Council support proposal to “minimise the impact of floodlighting” in regards to Chelmsford City Racecourse. Wish to have “and noise” added to the policy to prevent noise pollution in Parish.

Resident/Community Associations

Howe Green Community Association

Site or topic Main Issues General • To preserve as much of the attractive countryside around Chelmsford as possible, the association state the new developments should be primarily within the existing urban area, on brownfield sites where possible. • Requested reconsideration of plans to generate a more equable division of developments between existing communities. Unfair that Danbury is only required to accommodate 100 dwellings, whilst Sandon is to contribute 400 dwellings on greenfield sites. Infrastructure – Road • In/Around Chelmsford, Colchester and Maldon, the existing System road infrastructure close to capacity. Further residential developments will cause substantially more traffic and additional congestion at peak times. • Chelmsford will become regularly gridlocked thus negatively impacting the prosperity or the city, deterring people from coming to the area. • They refer to Page 24, Figure 6 of Essex County Council’s “Chelmsford’s Future Transport Network” showing that as of 2014, the present road network was at 96% capacity and this is to reach 100% before 2020. This is without any consideration for future development under the next local plan. • Feel funding is, and will continue to be, a significant issue. Not enough money going into the maintenance of the road systems as it stands resulting in condition of local roads to be worse now than for several decades. Site 3a – Land north • Expressed objection against plans to develop within the river of Maldon Road – valley and into land previously designated as “green wedge” to Residential preserve the rural landscape. Development • Development plans for north of the A414 will lead to limitless development in the area, eventually covering the river valley and remains of green wedge, worsening traffic flow. • Plans to develop this area were rejected in 1970’s/80’s, with this decision supported by planning officers. Appendix 1

• LPA cannot guarantee “high quality residential development” or “non-standard housing types”. • No requirement for country park other than to consolidate this large intrusive residential development. Area is already served by Danbury Lakes and Sandon Quarry. Site 3b – Land north • See comments for 3a, object against plans. of Maldon Road – • Commercial activity to be introduced to the river valley will be Business Park significantly intrusive. • There is no description as to what “high-tech” development is. Feel this could be a deception. • To be consistent with concept of sustainable development, want consideration to reserve site for expansion of Park and Ride facilities. Car parking would be less intrusive than buildings. • Commercial activity planned for this site is not compatible with plans for site 3c. Site 3c – Land south • Association supports these plans of Maldon Road – • Tying in with comment above about equable division (see Residential above), this is perfect site for Sandon to contribute 150 Development dwellings, which should be Sandon’s total, as opposed to 400 dwellings • Support comments from Para 7.108 and 7.109 in Preferred Options Consultation Document.

Newland Springs Residents Association

Site or topic Main Issues General • The plan should be realistic in not proposing major infrastructure that cannot be delivered • The existing city road system is very close to capacity. To put development expecting existing roads to cope with the traffic generated by new development is unacceptable. New development should be sited close to good transportation infrastructure. Strategic Policy 1 • The growth locations in north and west Chelmsford are not proven in the evidence based to be consistent with the principles of sustainable development. • The Sustainability Appraisal Report, shows that the growth sites in West Chelmsford have significant negative effects on SA objective 14 (landscape) and SA objective 12 (waste and resources) Strategic Policy 5 • Finds it extraordinary that the IDP has not yet been agreed and therefore cannot be assessed in terms of its robustness and delivery. The IDP should have been agreed first and locations for development chosen that can be supported by the IDP Appendix 1

• Above point particularly relevant to North Chelmsford – with development underpinned by infrastructure as yet unassured (i.e. CNE Bypass) • The preferred option should have taken greater account of newly improved infrastructure such as the A130 South and the new Beaulieu railway station. • Current CIL Charging Schedule does not take into account Infrastructure Investment required to service the new Local Plan. How will infrastructure be forward funded and when will the Charging Schedule be reviewed? Strategic Policy 7 • There is insufficient evidence provided in any of the local plan documents to justify the permanent loss of Grade 2 land proposed in growth locations in the west and north. • Site allocations outlined later in the document do not ‘minimise the loss of the best and most versatile agricultural land to ensure future production’ and do not advance overriding ‘other planning factors.’ It is therefore considered that the Preferred Option is not the most sustainable option in this regard. Spatial Principles – Green • Green Belt and wedges are important, but so is the need to Belt and Green Wedges site new development in the right place. This may mean reconsidering the boundaries of the Green Belt and wedges. • There is undeveloped countryside that has greater value than that within the Green Belt i.e. the landscape character of Pleshey and Writtle Plateaus. Both will be adversely affected by development at Warren Farm. • Landscape and land quality much more suitable for development to the east and south of the city. • Development to the east of Chelmsford could also utilise the A12, A130, CNE Bypass and new rail stations. Far better for development than West and North Chelmsford where the existing road system is already very close to capacity. Strategic Policy 9 • Disagree that the proposed development locations nos. 2 (Warren Farm) & 6 (N of Broomfield) are in the most sustainable locations or that they meet the Spatial Principles set out in the Document • Development in the West and North of Chelmsford is clearly not sustainable – road system unable to cope with extra traffic and no significant new transportation infrastructure is to be provided. • It is difficult to understand the rational for not including Hammonds Farm as a site for development, given that it is deliverable in terms of providing infrastructure upfront, building a range of homes at the rate of 200 units a year. Appendix 1

Strategic Policy S12 & S13 • There will be no adequate transportation infrastructure for the proposed sites at Warren Farm and N of Broomfield and therefore these sites fail the test of sustainability. Site Allocation Policies – • Do not consider this location to comply with strategic Location 2 (Warren Farm) priorities, spatial principles or strategic policies • Not suitable for development due to increased traffic generation, no connection to cycle / walking paths, landscape sensitivity, loss of grade 2 agricultural land, mineral safeguarding area, flooding concerns, impact on health services. Site Allocation Policies – • Do not consider this location to comply with strategic Location 6 (N of priorities, spatial principles or strategic policies Broomfield) • Not suitable for development due to already congested road network. Most likely access would be by private car, due to expensive buses and poor cycle / walking paths. • In particular concern that a new one-form entry primary school would not be viable in the longer term. Proposal Maps • Do not agree with proposal maps 1 and 8 – previous comments apply.

Key Points Made by Visitors to the Public Drop-In Exhibitions

Broomfield 19/04/17 Number Attended: 15

Infrastructure/ traffic • Will Woodhouse Lane close? • Commentary in policy suggests access off Woodhouse Lane (which is a little confusing) • Not enough information in the plan about the new access road to the hospital • Broomfield cannot cope with any more development and does not have the infrastructure to support it, you cannot get out onto the roads at busy times already • All new development should be focused around the new train station.

Danbury 02/05/17 Number Attended: 57

General • Concern about any new development in Danbury Infrastructure • Concern about any new development in Danbury • A414 is clogged at peak times Appendix 1

• New traffic light system around Eves Corner is dangerous • Improvements should be made further east to allow Maldon commuters to bypass Danbury • Suggestions of southern bypass • Existing rat running is a problem • Danbury has to cope with traffic from Maldon’s growth – it can’t cope with any more Design/Layout • Would 100 homes be in addition to any appeals lost? • Do recent planning permissions (including corner of Butts Lane, and former doctors) count towards the 100 allocation? Environment • Concern about any potential development north-east of Runsell Green, specifically impact on wildlife (as well as openness and views)

Great Baddow 28/04/17 Number Attended: 64

Infrastructure • Maldon Road is already very busy and Sandon School and surgeries are full • Concern about the traffic impacts on Maldon Road, as well as the main vehicular entrance to serve all three sites • Could site 3a have an entrance in the western part of the site leading directly to the roundabout? • Concern about potential loss of Farm Shop • Concern that 3a is not providing any supporting infrastructure • Concern about how people will cross Maldon Road by foot/cycle from 3a and 3b Design/Layout • The row of trees to the north/north west of 3c were planted by the Forestry Commission in 1996, what will happen to them if new dwellings are meant to ‘front’ Maldon Road? • How is it possible to design 3c to minimise the impact of the electricity pylons, one of them goes directly through the site • The Country Park looks very small • A new road to Sandford Mill will not help local residents who are happy to walk to Sandford Mill using Sandford Mill Road • Concern development is creeping closer to Sandon • Resident of Molrams Lane would feel happier if the access to houses was from an interior boundary road to maximise distance between existing and new houses, rather than entrances and front gardens onto Molrams Lane Appendix 1

• Check alignment of water/gas pipelines on all 3 sites • Clarify what type of buffer would be provided around the 4 cottages on Molrams Lane Environment • There is contamination in the southern part of 3a from a former landfill site near what is now Baden Powell Close, inside Baddow Hall Crescent • Concern about impacts on wildlife on all sites, including specified biodiversity species

Great Leighs 27/04/17 Number Attended: 270

General • Significant objection Infrastructure • Significant objection • The Village is currently grid locked in rush hour and this will only make it worse. • Concern that a secondary school will also be needed. • Concern over the impact Braintree’s growth will also have on roads and schools. • People were unaware about the existing improvements proposed to the roundabouts. Design/Layout • There are listed buildings within the Moulsham Hall site which are privately owned. • Concern for the impact on buildings surrounding the sites and how the development will impact the setting and outlook of these properties. • Query why listed buildings are included in the red line on Moulsham Hall side • Suggestions that Moulsham Hall side could take more development to avoid other the areas G&T • Misunderstanding as to who are Travelling Showpeople • Queries over location within the parcels Environment • Confusion over why woodlands were included in ‘developable’ area

Little Waltham 18/04/17 Number Attended: 160

General • Concern over amount of development in NE Chelmsford and Broomfield Infrastructure • The Main Road is already too busy and will be worse with increased traffic. Appendix 1

• Village experiences rat running especially when congestion on ERW • Pleased to see an additional entrance to the Hospital. Design/Layout • Wanted to know more detail about where roads would go through the site and where the hospital entrance would be.

Sandon 02/05/17 Number Attended: 22

Infrastructure • Maldon Road and Molrams Lane are very busy already • Sandon School and surgeries are full Design/Layout • Molrams Lane is already very busy and it can be dangerous to cross to get to the pavement along the west of Molrams Lane, a new pavement along the eastern side would be a benefit • Houses on Molrams Lane currently have a great view over open countryside to the east, the impact and loss of privacy could be mitigated somewhat by having a landscaped open space to the front • Although houses should face Molrmans Lane there should be no vehicular access from here since the road is already very busy as it is, parking on this road/pavement needs to be prohibited with access to the houses being provided from the rear

SWF 24/04/17 Number Attended: 300

General • General objection to further development in SWF and proposal Infrastructure • Don’t mind the houses but only if the infrastructure is improved to support them. • Improvements to the A132 and the Burnham Rd are needed – what form will these take? • Concern over how people will cross the road to use SWF Town Centre and get to schools/railway station. • What improvements are being done to the roundabouts – people want to see how the roads can be improved. • Concern that coming out of Hulbridge Road currently is very difficult and some improvement is needed here. • What improvements are going to be made to the railway station • There are not enough secondary school places at William de Ferrers • Morning traffic peak is 7-8am not 8-9am as used in the traffic studies

Appendix 1

Design/Layout • Lots of people wanted to see the design of the houses/layout of the site etc. • Why have you ruled out development in other directions instead (e.g. east and west) G&T • Where will the TSP site be – there was a lot of misconception that this would be a transit site where travellers would come and go and there would be no control over it. • What is the definition of a travelling showman and how big is a travelling showman plot? Confusion between travelling showman and gypsies Environment • Flooding is an issue now and will be worse with more run-off from the development on the hill. Retail • Will the development also have local shops if Sainsbury’s is built?

Springfield 21/04/17 Number Attended: 11

Infrastructure • Don’t mind the houses but only if the infrastructure is improved to support them. • Supportive of the NE Bypass.

Writtle 05/05/17 Number Attended: 100

General • Objection to Warren Farm • Concern about consultation process e.g. overly complex Infrastructure • The roundabout is unlikely to be able to cope with traffic generated by the new development, an access from Roxwell Road, nearer to the urban area would be preferable (comment at High Chelmer) • Concerns about rat running in Writtle village • Concerns about traffic congestion into the City Centre from the site which is already bad at peak times • Concerns about safe crossing of Roxwell Road into the Green Wedge • Concern about lack of capacity in Writtle GP surgery and no provision on new development made Environment/Landscape • Flooding is an issue now and will be worse with more run-off from the development on the hill • Concerns about landscape impacts Appendix 1

• Concerns development would result in Writtle village merging with Urban Chelmsford

Other Exhibitions 7-29 April (County Hall, High Street, High Chelmer) Numbers Attended/Handed a Leaflet To: 900

• Chelmer Waterside sites

Vehicular access from Wharf Road will not be enough for a development of the size planned (CW1a and 1b). Would it be possible with another access to connect Wharf Road to the new Chelmer Road bridge?

The Council should promote the availability of recreational moorings; there seems little point is asking developers to pay for this infrastructure and then not ensure it is used. Should be more aspirational for Waterside sites, look at Lea Valley Park. • North of Gloucester Avenue (John Shennan Playing Field)

Concern from residents living across the road from the entry to John Shennan playing field that Gloucester Avenue is already very busy in the mornings and this development will make it even worse, there is also no pedestrian crossing.

This is the only open space in the area, where are children supposed to go? There certainly won’t be much open space left on this site after it has been developed.

The housing number proposed is very high for this site, it will generate approx. 400 new cars on roads that are already very busy all the way down to the Miami roundabout, you cannot expect people to cycle along Gloucester Avenue during busy times of the day.

The access to the playing field is very narrow with a house either side.

• Other City Centre/urban sites

Meteor Way – the figure (380) homes would appear very high for such a small site. Why does the red line enclose parts of the Green Wedge which is supposed to be protected?

• Concern that consultation was not advertised well enough – lack of posters • Paper copies should be free of charge to residents

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