Response to Braintree Local Plan

Feering Parish Council objects to the Braintree District Local Plan Regulation 19 draft, and in particular Policy LPR26 – Kings Dene, on the basis that the Plan is unsound.  In the Parish Council’s view, the Plan is not positively prepared, justified, effective or consistent with national policy as required by the NPPF.  It fails to demonstrate that the scale and location of growth proposed for Feering, Kelvedon, Rivenhall and the surrounding area can be delivered in a sustainable manner, with the necessary infrastructure in place and with proper regard to the character and function of existing communities.

The Plan relies too heavily on generalised assumptions, vague mitigation and uncertain future delivery, rather than firm, evidenced and enforceable commitments.  That is particularly apparent in relation to strategic transport provision, access to the A12, water and wastewater capacity, settlement coalescence, and the cumulative impact of major allocations.  The result is a Plan that cannot be regarded as robust or sound.

LPR18 – Strategic Growth Locations

Policy LPR18 is unsound.  The requirement for strategic growth locations to create integrated, accessible and sustainable transport systems, and to provide walkable, locally accessible community, employment and retail facilities, is not supported by evidence which demonstrates that this can be achieved in practice.  There is no adequate explanation of how Policy LPR26. Kings Dene, will be connected to Coggeshall, Rivenhall, Feering or Kelvedon by meaningful public transport, nor how residents will access essential services without substantial reliance on private cars.

The policy also fails to show how such development will genuinely integrate with adjacent rural and urban communities without overwhelming them.  In reality, the scale of Kings Dene would dominate the surrounding settlements rather than respect their character or function.  The wording of the policy is too imprecise and too dependent on future “appropriate” mitigation to be capable of effective delivery.

The Parish Council further objects to the proposal for green infrastructure on the basis that the Plan does not demonstrate that these areas will be functional, accessible or meaningfully integrated with surrounding communities.  The policy assumes benefits which are not evidenced, and which may not be deliverable in practice.

The requirement that infrastructure and road improvements be phased to ensure they are in place when needed is not strong enough.  For a development of this scale, essential infrastructure must be secured before occupation, not promised at some unspecified later stage.

LPR25 – Land at South East Feering

Policy LPR25 is unsound.  The policy refers to access to the A12 as a requirement, but the evidence does not show that current or proposed access arrangements are sufficient.  Without a proper all-ways junction, the development would place unacceptable pressure on surrounding roads and villages.  The Plan does not adequately address the consequences if the A12 route is disrupted, nor the likelihood of traffic rat-running through Feering and Kelvedon.

The policy also lacks certainty over transport mitigation.  The Parish Council notes that the Highway Authority has itself identified the need for further modelling and measurement.  In those circumstances, the allocation should not proceed on the basis of incomplete evidence.

LPR26 – Kings Dene

Policy LPR26 is unsound.  Although it refers to highway and transport improvements, including an A12 access junction and the Coggeshall Road/Oak Road link road, the policy is not sufficiently precise as to what must be delivered, when, and by whom.  The Parish Council considers that the infrastructure required to support this allocation must be delivered in advance of, or at the very least concurrent with, the earliest phases of development.

The policy is also inadequate in relation to green buffers and the prevention of settlement coalescence.  The indicative plans do not provide convincing protection against the merging of Kings Dene with Rivenhall and the wider settlement pattern.  This is contrary to proper planning of the area and risks the creation of an extensive continuous urbanised corridor.

LPR46 – Sustainable Transport

The Parish Council supports the principle of sustainable transport, but this policy is unsound insofar as it overstates the ability of active travel and public transport to meet the needs of the proposed growth.  The scale and location of development mean that many journeys will not be capable of being made conveniently by foot, cycle or bus, particularly before local services are in place.

The Plan gives insufficient weight to the practical realities of travel behaviour, including commuting to work and accessing schools, health services and employment centres.  The effect will be continued, and likely increased, dependence on the private car, contrary to the aims of the policy.

LPR49 – New Road Infrastructure

Policy LPR49 is unsound because the road infrastructure proposed is insufficiently certain, insufficiently funded and insufficiently detailed.  The references to “improved connections” and proposed strategic links do not amount to a deliverable infrastructure strategy for development of this magnitude.  The Plan must identify firm funding sources, delivery mechanisms and phasing arrangements.

Without this, there is no confidence that the infrastructure needed to support the Plan will be provided in time, or at all.

LPR71 – Green Buffers

Policy LPR71 is unsound because it does not provide sufficient protection against the coalescence of communities.  The proposed buffers appear inadequate to maintain clear separation between settlements, particularly in the Feering, Kelvedon, Rivenhall and Witham area.  The policy therefore fails to safeguard the identity, character and setting of these villages.

LPR75 – Energy and Water Efficiency

Policy LPR75 is unsound.  The policy refers to improvements to water infrastructure, wastewater treatment and drainage being made where necessary, but this is far too weak in light of the scale of growth proposed.  The Plan must be based on clear evidence that water supply and foul drainage capacity exists, or can be delivered, before occupation.

The Parish Council is concerned that the Plan does not adequately address the serious constraints on water and sewerage infrastructure in the area.  It is not sufficient to rely on future improvements, especially where the evidence suggests that existing capacity may already be under pressure.

LPR81 – Infrastructure Delivery and Impact Mitigation

Policy LPR81 is unsound because it is too vague and too flexible.  Terms such as “appropriate”, “deliverable” and “viable” are not defined with sufficient clarity to provide certainty.  The policy does not establish a robust and objective test for when development may proceed, and the exceptions to the policy weaken the requirement for full mitigation.

For a Plan of this scale, infrastructure must be planned, funded and phased with far greater certainty.  The policy should not allow major development to proceed where mitigation is incomplete, speculative or dependent on unclear viability assumptions.

This creates a serious risk that major development will be approved without the infrastructure needed to support it.  That is not a sound basis for a Local Plan.

Conclusion

For all of the above reasons, Feering Parish Council considers that the Regulation 19 Local Plan is unsound and should not be submitted for examination in its current form.  The Plan does not provide a credible, evidence-based or deliverable strategy for major growth in the Feering area.  It fails to meet the requirements of the NPPF and does not properly reflect the current Local Plan context or the objectives of the Feering Neighbourhood Plan.

The Parish Council therefore objects in the strongest terms and requests that the Plan be revised so that no further strategic growth is proposed in the Feering area unless and until there is clear, funded and deliverable infrastructure in place to support it.