Tendring Colchester Borders Garden Community Development Plan Document (DPD)

Essex County Council (ECC) supports the preparation of a Development Plan Document (DPD) for Tendring Colchester Borders Garden Community (TCBGC) and as a member of the Joint Committee will continue to work in close partnership with Colchester City and Tendring District councils to ensure the delivery of ECC’s statutory roles and responsibilities, so that TCBGC delivers a safe, green and healthy community with long term sustainable infrastructure delivery.

The content of the Draft Plan and its evidence base reflects our active involvement throughout all stages of plan preparation and ensures that the provision of ECC’s infrastructure and services for future residents and businesses are identified and can be delivered.

ECC has informed, supported and helped refine the formulation of the development strategy and policies to be delivered by the DPD. Our involvement is necessary and beneficial because ECC is:
• the Highway and Transportation Authority, including our responsibility for the delivery of the Essex Local Transport Plan; lead authority for Education including early years and childcare (EYCC), SEND, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority (LLFA); lead advisors on public health; and has responsibilities for adult social care in relation to securing the right housing mix which takes account of the housing needs of older people and adults with disabilities;
• an infrastructure funding partner which seeks to ensure that development proposed is realistic and does not place an unnecessary (or unacceptable) cost burden on the public purse and, specifically, ECC’s capital programme;
• a major provider and commissioner of a wide range of local government services throughout the county (and where potential cross boundary impacts need to be considered); and
• advocate of the Essex Climate Action Commission (ECAC) report “Net Zero – Making Essex Carbon Neutral” providing advice and recommendations for action on climate change mitigation including setting planning policies which minimise carbon. This work has been tailored for use in the county of Essex.

ECC considers that Colchester City and Tendring District councils have met its obligations under Section 110 of the Localism Act 2011 regarding the duty to cooperate with regard to those statutory responsibilities of the County Council, namely highways and transportation, education, minerals, waste, Public Health, Lead Local Flood Authority and adult social care.

There is strong support for the policies provided in the Draft Plan, which align with ECC priorities and commitments contained in our corporate plan Everyone’s Essex, and relevant service plans and strategies, such as:
• proposals for growth and development to meet housing and economic needs and the policy position to create balanced well-designed places;
• policies that relate to adaptable and accessible housing, and care assisted living and other specialist housing;
• policies, evidence and provision for education requirements and the need for a demographic study to confirm school requirements;
• policies and approach to health and well-being and the requirement to undertake Health Impact Assessments;
• policies and approach to surface water management, sustainable drainage, and multifunctional green and blue infrastructure;
• policies and approach to movement and connections, and the evidence and provision of transportation infrastructure and modal share targets;
• policies and approach to net zero and wider climate change ambitions;
• policy and approach to digital infrastructure;
• policy requiring a Minerals Resource Assessment to ensure the prior extraction of minerals is coordinated through masterplanning and the planning application process; and
• policies that relate to securing developer contributions to effectively deliver the necessary infrastructure and contributions so that ECC’s role as an infrastructure provider is not jeopardised, and that this is consistent with national policy and ECC’s Developers’ Guide to Infrastructure Contributions;

ECC will contribute to the examination in public and provide support for the Councils as appropriate and where this reflects our statutory role and responsibilities.

ECC welcomes and supports the vision for the natural environment to be the Garden Community's most valuable asset; in that nature will be placed at the centre of development to contribute and deliver environmental, health and wellbeing and economic benefits for people and wildlife.

The Draft Plan has integrated multifunctional green infrastructure / natural environment / green spaces throughout relevant chapters and polices, and it aligns with the Essex Green Infrastructure Principles and Standards, 2022. The Draft Plan meets the requirements set out in paragraphs 20, 92, 154, 175 and 186 of the NPPF by protecting existing and providing and maintaining GI to deliver multiple functions and benefits from the beginning.

On behalf of the Essex local authorities, ECC has established a Local Nature Partnership covering Greater Essex and is leading on the development of the Essex Local Nature Recovery Strategy. The strategy is a statutory requirement from the Environment Act and will comprise maps and proposed actions for nature's recovery that the Garden Community can contribute to, and applications will have regard to.

To strengthen the Draft Plan, applicants should have regard to the use of the Essex Green Infrastructure Standards, 2022 published in the Essex Design Guide in order to facilitate securing multifunctional green infrastructure. The standards have been supported and endorsed by Natural England, were prepared in consultation with all Essex local authorities (including Colchester City and Tendring District councils), and align with the National Green Infrastructure Framework. This framework includes a Developers and Design Teams Green Infrastructure process journey.

It is recommended the following is inserted as the last sentence in GC Policy 2, Part B:

“Proposals should have regard to the Essex Green Infrastructure Principles and Standards, 2022”.

Part B (Page 39). Green roofs are refenced twice in this section – in the second and fourth lines i.e., “green walls and roofs” and then “green roofs”. It is recommended that the second reference to “green roofs” is deleted and replaced with “dual purpose street furniture”. The design of street furniture and bin stores can add character to the landscape, reduce clutter, and benefit biodiversity.

It is welcomed that the overall policy wording for GC Policy 2 has been strengthened from the Regulation 18 Draft Plan (Spring 2022), demonstrating the commitment for the protection and provision of green infrastructure throughout the Garden Community. However, a further change is recommended to strengthen the policy.

Replace "should" with "will need to" in the last sentence of GC Policy 2: Part E (page 41):

“Areas for planting or regeneration will need to be set out and agreed in the appropriate landscape and green-blue infrastructure strategies and management plans.”

GC Policy 3, Part B (page 54). For clarity and consistency with other reference in the Draft Plan, it recommended that reference is added to the “multifunctionality” of green infrastructure.

Change the third bullet in GC Policy 3: Part B (page 54) to read as follows:

“Provide for a network of integrated multifunctional green and blue infrastructure features.”

ECC as the highway and transportation authority, supports Chapter 8: Movement and Connections, which seeks to create high quality sustainable connections and an environment that make walking, cycling and public transport the most attractive method of travel.

ECC has worked closely with Colchester City and Tendring District Councils to develop a place-based approach to achieving net zero carbon transport by 2050 for the Garden Community. Chapter 8 has been drafted in coordination with ECC to ensure a cohesive approach.

The provisions in the Draft Plan fit with a number of the strategic aims for ECC. The movement and connection chapter supports a strong, inclusive and sustainable economy; it will support a high-quality environment by encouraging people to use public transport; and it will support health, wellbeing and independence for all by improving connectivity. In particular it looks to deliver a step change in sustainable travel, by growing passenger transport and active travel, and will ensure we support the move towards net zero, climate resilient developments within this new proposed garden community, by delivering sustainable, healthy neighbourhoods for the future. This is demonstrated further as the Draft Plan is in line and consistent with the current Essex Transport Strategy: the Local Transport Plan for Essex (LTP3), and the overarching five broad outcomes:
• Provide connectivity for Essex communities and international gateways to support sustainable economic growth and regeneration,
• Reduce carbon dioxide emissions and improve air quality through lifestyle changes, innovation and technology,
• Improve safety on the transport network and enhance and promote a safe travelling environment,
• Secure and maintain all transport assets to an appropriate standard and ensure that the network is available for use, and
• Provide sustainable access and travel choice for Essex residents to help create sustainable communities.

Additionally under the LTP3 a number of the priorities for the Haven Gateway Area/ North Essex are being supported through the infrastructure and measures to be delivered:
• Providing the transport improvements needed to accommodate housing and employment growth in a sustainable way;
• Tackling congestion within Colchester (including the provision of Park & Ride facilities);
• Improving the availability, reliability and punctuality of local bus services;
• Improving and promoting cycle networks; and improving the availability of travel choices and awareness of them; and
• Improving journeys for commuters travelling to London from Colchester and Braintree; particularly by improving access to railway stations and improving facilities for passengers.

GC Policy 8, Part I (page 120). The justification for GC Policy 8 and Part E states it is essential to demonstrate how the proposed planting palette includes adaptable/resilient plant species. It then states that details should be submitted as part of the application of appropriate biosecurity standards for sourcing, quarantining, and inspecting plant material supplied to the development. To ensure consistency and clarity, Part I should reiterate the need for this to be set out in the Green and Blue Infrastructure Plan.

ECC welcomes that the Essex Climate Action Commission (ECAC) is mentioned in the justification for GC Policy 8 on page 121. The Garden Community is situated within the ECAC’s recommended Climate Focus Area (CFA), which is formed of the Blackwater and Colne River catchment areas. The principal objective of the CFA is to become net zero carbon – meaning that the amount of carbon emitted from the area is no higher than that absorbed. The GC can contribute to the CFA targets.

Accordingly, the Policy Justification can include a new sentence at the end of the second paragraph.

“It should also be noted that the Garden Community is located with the ECAC Climate Focus Area (CFA). The principal objective of the CFA is to become net zero carbon – meaning that the amount of carbon emitted from the area is no higher than that absorbed. The Garden Community can contribute to the CFA targets.”