Tendring Colchester Borders Garden Community Development Plan Document (DPD)

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.

Compliance:
I consider that the Development Plan Document is Legally compliant.
It is not sound for the reasons stated below.
I consider that the document complies with the statutory duty to co-operate, but the consultation process using the engagement website is overly complex and biased. It seems likely that many people will have been deterred from participation in the consultation by these arrangements.

I would be pleased to participate in the oral part of the examination if this would be of assistance.

GC Policy 1: Land Use and Spatial Approach.

• The Garden Community Principles unproven. The GC vision overly aspirational and adopts a naive perception of the way in which communities are established and of human behaviour. The latter is not simply determined by environment.
• The GC is unlikely to address a local housing need, unless a greater proportion of rented housing is included. The present proposed approach will encourage further migration from the London suburbs, by the property wealthy whose pattern of work has changed post Covid-19.
• Many prospective residents of the GC will not be seeking local jobs, they will be occasionally commuting to London and working from home.
• Unrealistic assumptions are made in relation to the extent to which private car usage will be reduced by the RTS and other more sustainable transport initiatives.
• The practicalities of community ownership are unclear.
• Shared ownership and rented housing should be included in the DPD as separate categories and the possibility of transferring from rent to shared ownership should be included.
• I was told at a consultation event that environmental requirements for new homes cannot exceed current building regulations, this is not clear from the DPD, which suggests the environmental requirements will be much higher.
• The neighbourhood map does not clearly distinguish between the North and Crockleford neighbourhoods.
• The development of the TCBGC does not justify the concreting over of a large part of rural northeast Essex.
• It does not seem logical that two proposed garden communities in north Essex were not considered to be viable, while the TCBGC is considered viable.

Policies Map:

• The need for 7,500 new homes in north Essex is not clearly established.
• A development on the Bromley Road has recently been curtailed because the developer’s expectation of potential sales has been reduced. Properties have also been sold to a London Borough to house homeless families.
• 1,000 to 1,500 new homes on Crockleford Heath will adversely impact on the special character of the area.
• The need for Knowledge Based Employment Land is not established, many the existing units at the University for Knowledge Based Employment remain vacant.
• The need for provision for Gypsies and Travellers is not supported by evidence.
• The term Green Links is not clearly defined. Are these for wildlife or walkers and cyclists? How wide are these corridors? A minimum of 100m may be appropriate.
• While Wivenhoe and Elmstead are provided with Strategic Green Gaps, why is no Green Gap provided for Crockleford Heath to preserve the special character of the area?
• The present proposals suggest that housing development to the south of the Bromley Road will encroach on Crockleford Heath. A Green Gap of at least 100m may be appropriate. Alternatively, given the high volume of traffic it may be appropriate not to develop any housing to the immediate south of the Bromley Road.

Policy 2: Nature.

• Nature and biodiversity are likely to be enhanced if housing development does not proceed.
• It is not clear how the safety of public spaces will be assured, and anti-social behaviour managed.
• Churn Wood is shown on the Framework Plan, but it is not made clear this is privately owned and does not have public access.
• What is an edible walkway – a licence to steal apples?
• How will community gardens be managed and maintained? If this is not clear these areas could become a focus for anti-social behaviour.
• This chapter of the DPD demonstrates an idealised and unrealistic approach to the relationship between people and nature. Many of the prospective residents of the GC may have little experience and knowledge of nature and little desire to develop such knowledge.

Policy 3: Place Shaping Principles.

• This chapter is commendable, but highly aspirational. It is not clear how quality of life, livability, equitable prosperity, and social cohesion are to be achieved in practice.
• Communities are not created by distinctive buildings. It is difficult to envisage that the TCBGC will not simply be another large housing development.
• There is a limit to which environment can have a positive impact on societal behaviour and crime can be designed out. Crime is a variable feature of human behaviour. It also reflects the quality and level of policing and other factors.

Policy 4: Meeting Housing Needs.

• There has been significant housing development around Colchester in recent years. Predominantly this has not met a local housing need, but has fuelled movement of people from other areas, particularly London It is difficult to imagine that if it proceeds the TCBGC will not have a similar pattern of home ownership.
• Residents on low income are likely to seek rented housing, from a provider of social housing and in this respect the chosen developer may be well placed to meet this need.
• To conflate shared ownership and rented housing in 30% figure for affordable housing is misleading. A greater proportion of rented housing may be necessary to meet local need.




Policy 5: Economic Activity and Employment.

• The objective of achieving one job per household in or near the garden community may be ambitious and will be dependent on factors such as the overall economic picture.
• It seems likely that a significant proportion of prospective residents will be employed in London and working remotely from home some of the time.

Policy 6: Community and Social Infrastructure.

• This section of the DPD is highly aspirational. Dependent upon the level of stewardship and management, what may emerge in practice could be very different.
• It is not clear whether multifunctional community buildings include the provision of healthcare services. This may be difficult to achieve in practice, given specialist medical needs.
• Management and longer-term stewardship of community provision of this nature could be clearer in DPD.

Policy 7: Movement and Connections.

• This policy section assumes that residents of the GC will adopt significantly reduced use of personal private cars. This may not be a realistic assumption.
• Similarly, neighbourhood delivery hubs will not be viable if residents choose to do their shopping outside of the neighbourhood centres by car in local supermarkets.
• The RTS will be operating on roads into Colchester City and will be subject to the same traffic delays as exist currently.

Policy 8: Sustainable Infrastructure.

• This policy is commendable but does not seem to be reflected in in the design requirements for buildings in the GC.