Representations in Respect of the Colchester Publication (Regulation

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Representations in Respect of the Colchester Publication (Regulation Representations in respect of the Colchester Publication (Regulation 19) Draft Local Plan On behalf of Bloor Homes 11 August 2017 1. Introduction and Background 1.1 These representations to the Colchester Borough Publication (Regulation 19) Draft Local Plan (the PDLP) are submitted by Strutt & Parker LLP on behalf of Bloor Homes, who are actively promoting the residential development of land at Maldon Road, Tiptree (SLAA reference C104/ TIP09). Representations have been submitted previously to the Preferred Options Local Plan (2016) (Regulation 18). 1.2 Land at Maldon Road, Tiptree represents a sustainable and deliverable site capable of accommodating new homes to help meet local housing need and to support the community of Tiptree. The site measures approximately 10 hectares and is capable of delivering up to 250 dwellings. The site is situated to the north west of Maldon Road, on the western side of the village, adjoining the existing settlement boundary of Tiptree. The site is well located relative to existing village services and is in single ownership; The site accords with National Policy deliverable criteria set out at paragraph 47 and is available, suitable location and achievable. A plan showing this site is provided as Appendix 1 to this submission. 1.3 Bloor Homes is one of the largest house builders in the UK. They have a proven track record of delivering new homes across a range of sites, with a local East Anglian team designing and building homes in the area. Bloor Homes’ current developments are located locally at Earl’s Garden Sible Hedingham, Kingswood Heath Colchester and Rowhedge Wharf, Rowhedge. They are also taking forward strategic developments in Chelmsford, Halstead and elsewhere across the County, working successfully with local authorities. 1.4 Bloor Homes has been actively promoting the site through the Tiptree Neighbourhood Plan, in addition to the Borough’s emerging Local Plan. A copy of the Concept Statement submitted to the Tiptree Parish Council Neighbourhood Plan Call for Sites in July 2017 has been provided at Appendix 2. 1.5 In respect of the PDLP, whilst the general approach to Tiptree as a sustainable settlement is strongly supported, we are of the view that the emerging Local Plan is not sound or legally compliant in its current form and some alterations are required to address these defects. This representation sets out the elements of the Local Plan that are supported, as well as the specific elements considered unsound/ not legally complaint; detailing why; and setting out proposed solutions to ensure the Local Plan is sound and legally compliant. The format of our written representations comprise this Written Representation Statement, completed response forms for each relevant policy, site location plan and Concept Statement submitted to the Neighbourhood Plan consultation. These representations focus on policies SG2, SG8 and SS14 and provide comments on the effectiveness of the Plan; the justification of the Plan and policies; and whether the Plan accords with national policy. We therefore consider the PDLP does not satisfy the tests of soundness, as set out by Paragraph 182 of the National Planning Policy Framework (NPPF). 2. Representations Policy SG1 - Colchester’s Spatial Strategy SUPPORT 2.1 Section 12 of the PDLP sets out a settlement hierarchy. We support the principle of a settlement hierarchy identifying the Borough’s main settlements and its use as a framework for the distribution of development and site allocations. 2.2 Paragraph 12.9 and Table SG1 identifies Tiptree as a Sustainable Settlement. We strongly support the appropriate identification of Tiptree as a higher order, sustainable settlement within the Borough’s settlement hierarchy. Tiptree is a District Centre supported by a number of key services and community facilities, such as two supermarkets, 4 primary schools, a secondary school, a community centre and a range of shops, cafes and restaurants. Policy SG2 – Housing Delivery OBJECT 2.3 Whilst we support the settlement hierarchy, it is important that the Local Plan does not adopt an overly prescriptive approach to the distribution of housing. We encourage the Council to identify an appropriate balance of small, medium and large sites which can maintain a consistent delivery over the plan period. Sites within sustainable settlements, such as land north of Maldon Road, Tiptree, are capable of delivering housing in the short term given they are not exposed to long lead-in times. 2.4 The proposed spatial strategy for North Essex and Colchester is focussed on delivering significant strategic development over the plan period, reliant on the delivery of infrastructure and investment. As part of the spatial strategy additional growth will be delivered in sustainable settlements. The NPPF highlights the importance of ensuring strategies are deliverable (paragraph 182), and that a constant five-year housing land supply is sustained over the plan period (paragraph 47). The NPPF also requires the strategy for meeting objectively assessed housing needs to be sufficiently flexible to respond to change (paragraph 14). We therefore consider that Policy SG2 of the PDLP is amended to emphasise the need for deliverable sites across the plan period. 2.5 Paragraph 47 of the National Planning Policy Framework seeks to boost significantly the supply of housing. As such, housing targets should not be considered as a maximum requirement or a ceiling for an area and should instead represent a minimum. Policy SG2 apportions 600 new homes to the settlement. Whilst we support the principle of additional dwellings at Tiptree, it is suggested that the wording of the policy is amended to express this new level of development as a minimum for sustainable settlements to encourage and boost the delivery of housing in the Borough. 2.6 Proposed amended policy wording: Policy SG2-Housing Delivery The Local Planning Authority will plan, monitor and manage the delivery of at least 14,720 new homes in Colchester Borough between 2017 and 2033. The housing target is based on a robust Objectively Assessed Housing Need figure of 920 homes a year and provides alignment with the targets for the delivery of employment land. The overall distribution of new housing, as shown in Table SG2, is guided by the settlement hierarchy set out in the Spatial Strategy and Policy SG1. New housing development will be focused on the following key areas: Colchester urban area (Place policies for Central, North, South, East and West Colchester) Tendring / Colchester Borders Garden Community (Section 1 Policy SP8) Colchester / Braintree Borders Garden Community (Section1 Policy SP9) Detailed decisions on the location, type and level of development to be carried out in the Garden Communities will be made through joint plans to be agreed with the relevant local planning authority, either Braintree (west) or Tendring (east), as outlined in Section1 of this plan. To maintain the vitality and viability of the Borough’s smaller towns and villages, an appropriate level of new development will be brought forward in Sustainable Settlements to support new homes and economic and social development across the plan period. Details on those allocations are provided in Policies SS1- SS16 (Sustainable Settlements) and expressed as minimum targets. Policy SG8 – Neighbourhood Plans SUPPORT 2.7 The PDLP seeks to encourage towns and villages to plan for the specific needs of their communities by developing Neighbourhood Plans. We are strongly supportive of the preparation of Neighbourhood Plan for Tiptree settlement. Policy SG8 – Neighbourhood Plans OBJECT 2.8 Whilst we are supportive of the principle of neighbourhood planning, we do consider that Policy SG8 should be amended to expressly state the need for neighbourhood plans to boost the delivery of housing provision. Recognition that housing targets should not be seen as a ceiling to delivery, as referenced at paragraph 2.5 of this Statement, will assist to achieve the PDLP’s sustainable growth, natural environment and places objectives and National Planning Policy (paragraph 47). 2.9 The spatial strategy for North Essex and Colchester relies on a significant number of dwellings to be delivered as large strategic allocations, reliant on the provision of extensive infrastructure which is time-consuming prior to housing delivery. Beyond these large strategic sites sustainable settlements will prepare neighbourhood plans to direct growth in their areas. As a result, the Local Plan relies on significant number of homes coming forward later in the plan period. It is therefore requested that the policy is amended to encourage the delivery of homes through neighbourhood plans across the plan period to ensure that a constant five-year housing land supply and delivery is sustained over the plan period (paragraph 47). 2.10 The NPPF requires decisions to be justified and based on proportionate evidence (paragraph 182). The SA/SEA does not consider an alternative to the currently drafted Policy SG8. As such, it is necessary for the PDLP to consider housing delivery through neighbourhood plans as a minimum and not for the proposed dwelling numbers to be treated as a ceiling. 2.11 Proposed amended wording: Policy SG8: Neighbourhood Plans Towns and villages are encouraged to plan for the specific needs of their communities by developing Neighbourhood Plans. The Local Planning Authority will support Parish and Town Councils and Neighbourhood Forums (in unparished areas) to prepare Neighbourhood Plans containing locally determined policies to guide land use and meet future development needs in their areas early in the plan period. Neighbourhood Plans will include policies relating to housing delivery which will boost the delivery of housing for their areas. Neighbourhood Plans are being prepared for Eight Ash Green, Marks Tey, Stanway, Tiptree, West Bergholt, Wivenhoe and West Mersea. In cases where a Neighbourhood Plan fails at any time prior to being made, responsibility for all planning policy matters within that plan area will revert back to the Local Planning Authority.
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