The CCC Local Plan and the ECC Minerals Local Plan seem to be out of step. The ECC Minerals Plan, 2014, indicates that areas in East Colchester, included for housing in the Plan are a minerals safeguarding area. These 2 plans are be incompatible. ECC's current view on minerals safeguarding is required to determine whether the proposed East Colchester Housing is possible.
The Essex Local Transport Plan must identify improvements to the road network, bus services, and train services. The Rapid Transport System has yet to prove its worth, as have the many cycle lanes built within the boundary of the City. Many areas are, and will remain, dependent upon the car for the primary mode of transport.

Please use authentic Traditional Architecture Design Codes as illustrated in my PDF umbrella Representation as these will support all key stakeholders ranging from property owners to the Local Authority itself and the community on strong economic, ecological and environmental grounds. Place a Ban on demolition of buildings constructed prior to 1950 and grant full protection of historic buildings, be these listed, Non-Designated Heritage Assets or otherwise.

Messing cum Inworth Parish Council (McIPC) submits this formal representation on Policies ST5,
PP19 and PP48 in Colchester City Council’s ‘Preferred Options Draft Local Plan’.
McIPC also submits formal representation on the following Evidence Base and Supporting
Documents:
• Summary of Sites Evidence Colchester Local Plan. October 2025 - Policy PP19
• Summary of Sites Evidence Colchester Local Plan. October 2025 - Policy PP48
It has strong concerns as follows:
Policy ST5 Colchester’s Housing Needs
Paragraph 3.51 States that allocation PP19 includes land within Tiptree Parish and Messing
cum Inworth Parish. McIPC believe the entire allocation for PP19 is within the Messing cum
Inworth Parish, including the proposed 27 hectares of open space. McIPC therefore welcomes
the opportunity to comment below.
Policy PP19 - Summary of MCiPC Concerns:
McIPC has concerns regarding this 600-house allocation that borders Tiptree but sits within
McIPC, opposite the woodland band separating Tiptree from Messing, as follows:.
● Traffic from this site could cut through Messing and along New Road.
● The plan does NOT include any mitigation to stop rat-running into Messing roads.
● The site is admitted to be in Messing-cum-Inworth Parish, even though it functionally serves
Tiptree.
The Policy sets out mandatory requirements as follows:
● 600 new dwellings and required Northern Link Road (B1022 ↔ B1023).
● Delivery of a Tiptree Country Park (27 ha).
● Must buffer Eden Wood and Inworth Wood.
● Provides pedestrian links and green corridors.
● Consideration to the inclusion of a mobility hub.
● Warns of possible heritage and archaeology impacts.
● Requires a detailed masterplan developed with the community.
Summary of Sites Evidence Colchester Local Plan October 2025 Policy
PP19
This acknowledges:
● Some highways constraints, but “not significant enough” to stop deliverability.
● Harm to biodiversity due to ancient woodland proximity.
● Need buffers and retention of hedgerows including a “green lane”.
● The site lies in Messing-cum-Inworth Parish, not inside the Tiptree Parish boundary.
● Greenfield land.
Site allocated in Policy PP19 Tiptree (but allocation in Messing cum
Inworth Parish Council) – Land North of Oak Road
The evidence summary for this site notes only minor “constraints” on highway access. Policy
PP19 proposes 600 homes and explicitly requires delivering the northern link road as per the
Tiptree Neighbourhood Plan. This link road would relieve Tiptree centre. However, until this
is built, new traffic from this development could divert through New Road into Messing. This
narrow country lane is very unsuitable.
McIPC request that strict traffic mitigation is required, and any planning permission for this
allocation should require a construction traffic management plan preventing heavy vehicles
from using the country lanes leading into Messing. Weight limits should be imposed on
Messing village roads during works. This should be a stipulation of the Master Plan or included
in Policy PP19.
The policy’s encouragement of a “mobility hub” or public transport provision is welcomed, as
there are no local bus services.
McIPC agree with the requirement in PP19 that the link road should be delivered, but McIPC
request that no additional traffic is routed through Messing’s country lanes whilst awaiting
the completion of the link road.
Environmental points are also noted, with the site containing parts of Eden Wood and Inworth
Wood (ancient woodland and Local Wildlife Sites). The Preferred Options allocation excludes
the Eden Wood area, and PP19 mandates buffering both protected woodland and retaining
the “green lane” hedgerow network. McIPC consider that these ecological safeguards must be
enforced, with no encroachment and the creation of meaningful buffers, and the proposed
27 ha country park to benefit the local area.
McIPC welcome the opportunity to be involved from the early stages of the consultation
process for the Masterplan for this development.
Policy PP48 - Summary of MCiPC Concerns:
McIPC has strong concerns for:
● Transport: No bus service, unsafe roads, long walking distances to bus stops.
● Traffic impacts: Narrow lanes; high volumes; Oak Road Tiptree traffic also likely to use New
Road → Messing → Inworth Road.
● Flooding: 2015 surface-water problems affecting site 10634.
● Sewage capacity: Pumping station frequently fails; tanker reliance.
● Heritage: Conservation Area and danger of HGVs on the tight bend near the churchyard wall.
● Services: School oversubscribed; poor electricity and internet.
The Policy sets out mandatory requirements as follows:
● Approximately 25 dwellings, compatible with surrounding development.
● Access from Kelvedon Road and must not harm highway safety or be detrimental to highway
capacity
● Require pedestrian links to existing footways and green infrastructure connections.
● Must provide 1.7 ha open space (important for drainage and buffering).
● Must deliver standing freshwater habitat (supports McIPC’s drainage concerns).
● Requires screening with hedgerows/woodland to preserve rural character.
● Must conserve heritage assets (Conservation Area and many listed buildings).
● Must not discharge surface water to foul sewer (aligns with McIPC’s concerns over sewer
capacity).
● Wintering bird surveys required.
Summary of Sites Evidence Colchester Local Plan October 2025 Policy
PP48
The Site passes SLAA Stages 1 & 2 under site allocation 10634
Issues noted:
● Some access constraints but deemed manageable.
● No potential harm to heritage assets(although it does state that a Proforma Heritage Impact
Assessment is required)
● Opportunities for green infrastructure.
● States site is a logical extension, reduced in size from what was promoted
McIPC however note the following issues with The Sites Evidence Document:
● It does not identify flood risk as a constraint.
● It identifies access issues. – (But not significant enough to affect deliverability)
● It identifies no heritage or character issues
● It does not identify any issues relating to density and impact on character
●It does not identify issues with utility provision.
Settlement Evidence Stage 1 - November 2024 Document
McIPC would like to clarify that although the population of the parish of Messing-cum-Inworth
is circa 166 households, 34 of these households are located in Inworth. The village of Messing
has only 132 households
The 2017 Settlement Boundary Review identified the sewage, drainage and surface water
capacity and (surface water) flooding issues that would need to be addressed if any
development were proposed. This was not identified in the November 2024 Settlement
Evidence Stage 1 Report. The 2017 Settlement Boundary Review stated that Messing should
only be considered for limited small-scale growth. It concluded that an earlier promoted site
for 21 houses was too large and vehicular access would be difficult to achieve. Messing was
not considered sustainable or suitable for planned housing growth. Since 2017, none of these
facts have changed.
Policy PP48 – Kelvedon Road, Messing
McIPC consider the City Council’s evidence presents an overly optimistic view of the site’s
suitability and its lack of harm.
The City Council’s Summary of Sites Evidence (October 2025) states that highway constraints
are “not significant enough to affect deliverability”, that there are “no known issues with utility
provision”, and that no adverse heritage or archaeological impacts are anticipated. It also
concludes that the site would form a “logical extension to the village.”
a) Transportation and Accessibility
● The Local Plan’s description of bus access and bus stop locations is factually inaccurate.
Colchester Preferred Options Local Plan document (Point 5.424) includes the statement “Site
10634 is located some distance from a railway station and cycling route, although it is close to
multiple bus stops”. McIPC would like to clarify that the closest bus stops are 0.9 miles (20
minute walk), 1.1 miles (25 minute walk) and 1.2 miles (25 minute walk)
● Walking routes to bus stops pose measurable safety risks. The village is served by narrow,
twisting country lanes with no pavement and a 60mph speed limit.
● The site (PP48) fundamentally conflicts with Paragraphs 109 to 118 of the NPPF and also
Colchester’s sustainable transport policy. With just 2 buses per week, (both on the same day)
and a road network that is conducive to neither cyclists nor pedestrians, cars are the only
practical means of transport. Siting development in the village goes against Colchester City
Council transport policies and objectives. Policy PC2 (Active and Sustainable Travel) states “All
new development should be planned around a network of safe and accessible active travel
routes, creating places that maximise opportunities for active and sustainable travel”.
● To achieve compliance with sustainability duties and requirements in accordance with
National and Local Planning Policy, the proposed policy should require the submission of a
Travel Plan (Paragraph 118 of the NPPF).
b) Road Infrastructure and Traffic
● The City Council’s evidence underestimates the severity of local road constraints and does
not account for the combined impact of committed developments in Tiptree, Feering and
Kelvedon. (NPPF paragraph 116 refers to the cumulative impact on highway safety….taking
into account all reasonable future scenarios). High volumes of traffic from Land North of Oak
Road, (PP19 allocation for 600 houses) is likely to use New Road as a cut through to Messing
and onto the Inworth Road. This road is VERY narrow and totally unsuitable for traffic volumes.
● Local traffic volumes are already high. The levels of development included in the Local Plan
for the Tiptree area, added with the plans that Braintree District Council are working on for
the development of Feering and Kelvedon, will lead to a large increase in vehicle traffic in the
district. There are already pinch points creating long delays at peak times at the Blue Anchor
and Factory Corner in Tiptree. With no plans to increase the current road infrastructure, there
is no doubt that delays will become more frequent and more widespread.
● The road network servicing Messing village is largely narrow single-track with passing places
forced from farmer’s fields, unadopted and therefore not maintained (with large potholes and
ditches presenting major dangers to road users). This road network also presents specific
dangers to pedestrians, cyclists and horse riders. Junctions leading onto local B-roads are also
narrow with impeded sight lines. On the assumption that each dwelling will have at least 2
vehicles, the proposal for 25 dwellings in Messing village will represent a significant increase
in traffic volume in the surrounding road network, especially when the almost total lack of
public transport is taken into account
● McIPC strongly request that a weight limit for vehicles entering and leaving the conservation
areas should be enforced during the construction phase.
McIPC request explicit traffic mitigation, including:
● A highways-led review of New Road
● Safety measures prior to progression of the Tiptree Oak Road allocation (PP19) and sites
already consented in Oak Road.
● Construction-phase restrictions to protect the Messing Conservation Area
c) District traffic management
McIPC note that no mitigations are currently proposed in response to the cancellation of the
A12 rebuild project. McIPC also note that Hinds Bridge (a narrow historic bridge, that does not
allow for large vehicles to pass) on the B1023 in Inworth is also excluded from any mitigations.
This is an ancient brick-arch bridge built in 1850 and closed for repairs in 2018 by Essex
Highways because the structure was sub-standard and failed assessment.
d) Heritage and Village Character
● McIPC are concerned that the general level of development throughout the district will have
an adverse effect on the centre of Messing, which is a Conservation Area with a high density
of Listed Buildings. As set out in paragraphs 202 to 214 of the NPPF, Designated Heritage
Assets and Conservation Areas need to be protected. The village already sees elevated traffic
levels when there are problems with the A12. Messing has had issues with HGVs attempting
to pass on the double bend by the church. Swept path analysis shows that this is impossible
due to the curtilage listed churchyard wall located in the inside of the double bend. McIPC
request that provision is made to ensure that HVGs are not permitted as through traffic in the
village centre.
e) Flooding and Surface Water Management
●The site (PP48/10634) has a documented history of surface water run-off problems. In 2015
Essex Highways investigated incidents of surface water flooding in Messing. (See Messing
Flood Study Report 2015 and its Appendices attached). Site 10634 was identified as a source
of the problematic surface water run-off. The Essex Highways Flood Study Report (January
2015) made a number of recommendations (including some relating to site 10634) to resolve
the problems. These mitigation works were undertaken, including works on site PP48/10634
(see Appendix D of the Flood Study Report). Any development work on site 10634 needs to
ensure that the mitigation works are not affected, otherwise this could cause surface water
flooding issues for both the site and the village.
● McIPC request that a site-specific drainage strategy, informed by the Essex Highways 2015
evidence, is a mandatory requirement for this site allocation. McIPC requests that clear
maintenance responsibilities are set out as policy, including a program of works, maintenance
and clarification as to who will take future maintenance responsibilities. In addition, discharge
of surface water from the development should be carefully designed so as not to add to the
local risk of flooding.
● McIPC would like to query why the historic surface water flooding issues and mitigation
works were not identified in the Settlement Evidence for this site.
f) Sewage Capacity
● Messing village is served by a sewage pumping station in Lodge Road. Sewage trucks are
frequently used to deal with excess volume, and residents have been informed that the
pumping station is at capacity and suffers from frequent failures. Further residential
development in Messing will require Anglian Water to increase the reliability and the capacity
of this pumping station to avoid environmental damage to the locality.
g) Density and number of units proposed
● The site allocation is for around 25 dwellings. McIPC request that the final number of
dwellings is determined through a detailed design process to ensure that the scheme reflects
the established character, grain, and density of the surrounding settlement. Any development
needs to integrate sensitively with the adjacent built form, maintain appropriate spacing, and
respect the transition between the settlement edge and the more open rural landscape
beyond.
● McIPC calculates the housing density along the section of School Road that directly backs
onto site 10634 at 23 houses per hectare. The nearby Collins Green development is calculated
at 14 houses per hectare, and the Messing Green development at 18 houses per hectare
(excluding the Green itself). Site 10634 should be designed to provide a density no greater
than the existing immediate area and definitely no more than 25 dwellings in total.
● There is an identified housing need arising from a recent survey carried out in conjunction
with the RCCE. We expect that this need would be satisfied within the stated 25 dwellings.
● Sufficient on-site parking should be included in the development to allow for the expected
3 vehicles per dwelling to avoid vehicle parking on the narrow lanes and village streets.
● The site will include green space of 1.7 hectares. The responsibility for maintaining this,
including the existing ditch, all hedges, trees, gardens and grassland, should rest with the
occupants of the new dwellings (perhaps via a management company) and not fall to existing
residents via the precept.
● Ideally, the green space should be a wetland area (swale/mere) to accommodate the
additional run-off that will result from the new development. This would help to prevent
surface water flooding issues at lower points in the village, including the area surrounding the
village hall. The wetland area would have the added benefit of increasing biodiversity, and if
the wetland area is sited between the existing houses in School Road and the new
development, the impact on the rural nature of the area will be lessened.
h) Utilities, schools and medical facilities
● Medical facilities
Messing residents make use of medical services in either Kelvedon or Tiptree. McIPC
understand that capacity is very limited for new patients in both locations. Although the scale
of development planned for site 10634 is relatively small, planned developments elsewhere
in Tiptree will make the provision of additional medical services a clear and urgent
requirement.
● Electricity supply
The existing supply to the village is unstable and residents report intermittent dimming of
lights. Additional development within the village is likely to exacerbate the situation unless
remedial work is completed.
● Data connectivity
Residents report frequent outages and slow running of broadband services. Further capacity
will be required to support the planned development.
● Education
Messing School provides for ages 5-11 – there is no nursery or pre-school service. The school
is currently over-subscribed. Alternative schools are available in Tiptree or in Kelvedon, several
miles away. The closest secondary school to the village is Thurstable in Tiptree. The majority
of village children aged 11+ attend that school. Other than those attending the village school,
pupils travelling to school are subject to the difficulties described in the Road Infrastructure
section above.
Messing-cum-Inworth Parish Council stands ready to work with the Planning department
and any subsequent developers to ensure that, should the proposed development proceed,
it is successful for both new and existing village residents

There would be inadequate access to health and social care as there is already insufficient capacity for existing population. Lack of public transport- no direct bus to BR station or hospital. Water, sewage and electricity networks are aging and overstretched. In event of island evacuation being required insufficient road access off the island due to tidal flooding. Any future developments will further impact on our already strained utility infrastructure.

I understand the need to get a Local Plan in place, to prevent rogue/speculative development.
I understand the volume of new houses to be built is provided to the Council by Government, which puts the Council between a rock and a hard place.
It is difficult to object to the policies regarding the new dwelling development, as such, although they are at such a high level.
I am pleased that Middlewick is excluded from this iteration of the Plan but expect that, as a result, there will be loud and vocal objections from other parts of Colchester, such as Berechurch, Langham or Marks Tey, where significant numbers of new builds are proposed instead.
What is unfortunately missing from the entire process is any considerations or benefits for Colchester’s many existing residents. Since the recent increases in housing in Rowhedge, for example, there is now a huge increase in through traffic in Old Heath. More houses are planned there (PP41) and, in the absence of regular or reliable public transport along Fingringhoe Road, it is highly likely that even more traffic past our house will inevitably result; it already difficult for us to get in or out of our own house, so 50 more dwellings will only exacerbate the problem. The ‘Abbot’s Road by-pass’ will only see an increase in traffic, congestion and air pollution, I would expect, in the absence of any other cross-town route available to the South of the town, and likely increased further by the 800 dwelling expansion off Berechurch Hall Road (PP10).
On the topic of traffic, the whole town is often choked with static traffic and not just at peak times. It’s all well and good building a Rapid Transit solution from Elmstead Market to Colchester, but when that depends in part on the existing ‘by-pass’ and bus lanes merging with, and disrupting, the flow of other traffic, then it is difficult to see the real benefits. Encouraging the majority of people to walk, cycle or take public transport seems doomed to failure, or hopeful at best, either due to indolence or excessive expense – it is more than twice as expensive for my daughter to take her family to town and back by bus, than it is to drive and park the car and, due to her husband’s disability, walking or cycling any distance is not an option, anywhere.
Once again, for existing residents in our area, there is no apparent provision for more school places (Old Heath, Rowhedge and Fingringhoe Primary Schools are already full), and I don’t see anything in the Plan regarding healthcare provision, either at the GP-level as a result of the new builds, or at the General Hospital, which are both bursting at the seams. It’s all well and good building roads ahead of houses, as is apparently the case for the Tendring Garden Community for example, but if other essential infrastructure such as schools, hospital and doctors surgeries are not also included in the overall Plan, then Colchester will just be left with several other different and difficult problems to resolve.

I understand the need to more housing, its a national issue, we must all play our part in.
However, there seems to be a lack or realist planning for "reality" going on, you seem to be ignoring "truths" because it does not fit your agenda.
Put in place realistic solutions for traffic, sewerage, electricity, public transport, doctors and school, then I could support you.

Comments as follows:
1. Positive to see the Roman River Corridor inclusion, and to see the high value Colne Valley landscapes recognised in the Landscape Character Assessment.
2. Positive to see mobility hubs and increased attempts at providing for sustainable transport.
3. Concern that the Brownfield Land Register remains very limited and focuses almost entirely on the urban area of Colchester. More should be done to proactively identify brownfield sites across the entire city boundary.
4. Concern that affordable housing delivery has only been 16% per annum on average for the past eight years and that the viability appraisals that accompany this plan must be rigrously tested to ensure that they are robust.
5. Concern that the strategy for Eight Ash Green results in car-dependent ribbon development along the 1124. Site PP32 should not be allocated. It represents unacceptable encroachment into the countryside.
6. Further concern that PP32 conflicts with the previous and latest Colchester Landscape Character Assesssments which seek to protect the Colne Valley. The site will be highly visible from Fordham and Chappel and cannot be screened. See attached by way of example. PP32 should not be allocated.
7. Allocation of Marks Tey North. All housing should be concentrated to the south of the site, in a high density development. Much of the Roman River must be kept inaccessible from residents and their dogs to ensure nature can flourish in the Nature Recovery area. The development must be safely connected to Marks Tey station by pedestrian and bike paths that do not use the polluted A120.
8. There should be minimum density requirements for all sites, not just urban ones.
9. The policy wording for conversions should change from 'only supported' to 'strongly supported.
10. There would be a policy to strongly support the bringing back of empty homes into use. An additional SA Monitoring indicator is required for number of homes brought back into use.

Regulation 18 Objection Draft Local Plan 2026–2041

Strategic Housing Allocation at Langham (~900 dwellings)

1. Introduction and basis of objection
This objection challenges the proposed allocation of approximately 900 dwellings at Langham on the grounds that it is unsound, when assessed against national policy, the plan-led system, and—critically—the Council’s own published reasoning in refusing major housing development elsewhere in the Borough. Colchester City Council’s refusal of a large-scale housing proposal at Maldon Road, Tiptree establishes clear and recent principles regarding spatial strategy, proportionality, countryside protection, infrastructure capacity, and the application of the presumption in favour of sustainable development. Those principles must be applied consistently. When they are applied to Langham, the allocation cannot be justified.
2. Failure of a genuinely plan-led spatial strategy.
In refusing the Tiptree proposal, the Council concluded that unplanned and unjustified growth which conflicted with the spatial strategy “went to the heart of the plan” and undermined the planned distribution of development. The Langham allocation represents precisely such a conflict. Langham is a small rural village with: • Limited local services • No railway station • Constrained public transport provision • A settlement form and function historically defined by its modest scale and countryside setting An allocation of approximately 900 dwellings constitutes a step-change in settlement role and hierarchy, rather than proportionate growth. It effectively elevates Langham to a scale of development unsupported by its accessibility, infrastructure, or sustainability credentials. Allocation within a draft plan does not, in itself, render development justified. The Council’s own refusal reasoning confirms that where the scale and location of development undermines the spatial strategy, the harm is fundamental. Applying that same logic consistently, the Langham allocation fails.
3. Disproportionate scale and unsustainable location.
In the Tiptree decision, the Council placed significant weight on the quantum of development combined with its location, noting that this created wider adverse impacts and demonstrated the importance of directing growth to suitable and sustainable locations. Langham is materially less sustainable than Tiptree. Directing strategic-scale housing growth to such a location conflicts with the principles of sustainable development set out in NPPF paragraphs 7–8 and the requirement in paragraph 20 for strategic policies to make sufficient provision for development in appropriate locations. The allocation is therefore not justified by evidence and does not represent an appropriate spatial response to housing need.
4. Countryside, landscape character, and settlement identity harm
The Council’s refusal at Tiptree relied heavily on national and local policy requiring development to: • Protect the intrinsic character and beauty of the countryside • Respond positively to local character and context • Avoid urbanising impacts that erode rural identity The Langham allocation would require extensive expansion into open countryside, redrawing settlement boundaries to accommodate large-scale built form, access roads, and associated infrastructure. The effect would be to urbanise the village’s rural setting and fundamentally alter its character and identity. As the Council itself concluded at Tiptree, landscaping and design mitigation cannot overcome fundamental harm where development is intrinsically incompatible with its context due to scale and form. That conclusion applies directly here. The allocation therefore conflicts with NPPF paragraphs 187–201 and relevant strategic policies seeking to protect countryside character and settlement identity.
5. Infrastructure failure – sewage and wastewater capacity
A central element of the Tiptree refusal was the failure to demonstrate that appropriate infrastructure capacity could be delivered and secured. The Council confirmed that development should not proceed where infrastructure impacts are inadequately addressed. At Langham, the draft Local Plan allocation is being advanced: • Without confirmed wastewater or sewage treatment capacity • Without committed upgrades • Without a delivery mechanism, funding certainty, or timetable Wastewater infrastructure is not optional or deferrable. In the absence of evidence that capacity can be delivered within the plan period, the allocation cannot be considered effective or deliverable. Allocating approximately 900 dwellings at Langham in these circumstances represents precisely the form of infrastructure-blind growth the Council described as unacceptable elsewhere in the Borough. This places the allocation in conflict with NPPF paragraphs 20 and 161–186 and undermines the credibility of the Infrastructure Delivery Plan.
6. Presumption in favour of sustainable development
In the Tiptree refusal, the Council confirmed that even where housing benefits exist, the presumption in favour of sustainable development is disapplied where adverse impacts significantly and demonstrably outweigh the benefits. At Langham, the cumulative adverse impacts include: • Disproportionate scale of growth • Harm to countryside and rural character • Unsustainable travel patterns • Absence of essential sewage infrastructure • Fundamental change to settlement role and identity Taken together, these impacts significantly and demonstrably outweigh the benefits of the allocation when assessed against the Framework as a whole. Applying the Council’s own reasoning consistently, the presumption in favour of sustainable development does not apply.
7. Soundness assessment
When assessed against the statutory soundness tests, the Langham allocation is: Not Positively Prepared It relies on unproven and unfunded wastewater infrastructure solutions. Not Justified The scale of growth is disproportionate and unsupported by a robust spatial rationale. Not Effective There is no evidence that essential infrastructure can be delivered within the plan period. Not Consistent with National Policy It conflicts with NPPF requirements on sustainable locations, countryside protection, and infrastructure provision.
8. Conclusion
The draft allocation of approximately 900 dwellings at Langham is fundamentally inconsistent with the Council’s own recent decision-making and fails to comply with national policy and the principles of a genuinely plan-led system. For the reasons set out above, the allocation is unsound and should be deleted or fundamentally reconsidered.

Observation: I comment as an individual/Salcott resident. The document on which residents are being invited to comment contains the equivalent of 200 pages of A4 text with in excess of 80,000 words. A pre-filter stage at the front end split by site would have simplified things no end for residents not au fait with such unwieldy systems.

A comment - it took me a little while to work out how to use this site and I worry that those digitally excluded residents may not be able to voice an opinion or may struggle to use this site - making it inaccessible for some

Local Government Reorganisation
Proposed Local Government Reorganisation in Essex, including the creation of a North Essex Unitary Authority, represents a foreseeable and material change to strategic planning and infrastructure governance during the early part of the plan period.
The draft Colchester Local Plan proceeds on the assumption that existing two-tier governance arrangements will continue and does not assess how the spatial strategy, infrastructure delivery or site selection would operate under future unitary governance, nor test reasonable alternatives in that context.
At Regulation 18 stage this means the Plan is not justified, as it fails to take account of a known strategic change when identifying options and developing the evidence base (NPPF paras 14 and 20).
These matters must be addressed at Reg18 stage, when options and strategic assumptions are still capable of being tested, and not deferred to a later plan review once reorganisation has already occurred.

Allot of the data for this is not available. The local transport plan is it of date. There is no support at a national level, which is needed to not cause further traffic chaos in the area.
The waste management is already under pressure, this is evident by the council adding extra burden on the residents to fund garden waste,a service the council previously funded.

Submitted by Marica Frost, Chair of Mersea Island Society. All other comments on the Portal from her are on behalf of the Mersea Island Society.

Mersea Island Society comments on the Colchester City Council Regulation 18 Consultation - Preferred Options Local Plan 2025

A Statement Outlining Concerns and Objections
Introduction

The Society was formed to preserve, safeguard and promote the characteristics of Mersea Island for the benefit of all, to arrange open discussion whenever it appears necessary to obtain a consensus of public opinion and to provide opportunities to gain factual knowledge from lectures, visits and discussion of this great island.

Mersea Island Society Committee wishes to formally express its opposition to the current draft Local Plan for Colchester. This statement outlines the principal concerns and objections that the Committee has identified, highlighting the potential impact on Mersea Island and its residents.
Key Concerns
1. Pressure on Local Infrastructure
2. Environmental Impact
3. Overdevelopment and Community Character
4. Lack of Meaningful Consultation

Summary of Objections
• Inadequate consideration of infrastructure limitations.
• Insufficient measures to protect the environment and manage flood risk.
• Overambitious housing targets that threaten the community’s character.
• Poor consultation and lack of engagement with Mersea residents and stakeholders.

Conclusion
In light of these concerns, Mersea Island Society urges Colchester City Council to reconsider the draft Local Plan. The Society requests a thorough review of the proposals as they relate to Mersea Island, with genuine engagement with the local community, robust environmental protections, and a realistic approach to infrastructure capacity. The Society remains committed to working constructively with all stakeholders to achieve a sustainable future for Mersea Island and the wider Colchester area.
The Society is concerned that the consultation process has not been sufficiently inclusive or transparent. There appears to be a lack of engagement with the specific needs and circumstances of Mersea Island.
The draft Local Plan proposes a level of housing growth that the Society believes is disproportionate to the size and character of Mersea Island. Such development risks altering the identity of the community, placing a strain on local services and undermining the qualities that make Mersea a desirable place to live and visit.
Mersea Island is a unique and fragile environment, home to diverse wildlife and protected habitats. The Society is deeply concerned that the scale and nature of the proposed developments threaten local biodiversity and undermine environmental protections. There is a risk of increased flooding and erosion, and the plan does not provide sufficient safeguards for the island’s distinctive landscape and ecology.
The Society is not opposed to very limited growth and for priority for housing to be given to local particularly young people but an additional 300 houses on top of the 200+ from the last local plan is unstainable.
The proposed development sites in the draft Local Plan would place significant additional pressure on the island’s already limited infrastructure. Concerns include the capacity of local roads, particularly the Strood causeway, as well as water supply, drainage, and waste management systems. The Society believes that these issues have not been adequately addressed within the plan nor the considerable pressure that arise from occupation of caravans. Neighbourhood Plan (2021) indicates there are 1,905 static caravans and lodges.

The Society will comment on specific texts in the Consultative Document. These to include comments on the evidence lacking in the consultation documents about the capacity for growth of West Mersea; provision of medical care and the aging population on the island; adequacy of the local Water Treatment Centre; our island position and flooding on the Strood severely affecting entry to and from the island; threats to environment resulting from overdevelopment; the site allocation on Dawes Lane; bus links and transport connectivity; ongoing consideration to SMR’s being located at the former nuclear power station at Bradwell, and the huge gap in money available for infrastructure improvements.

The Society urges that these comments be considered when further consideration is given. Mersea in many ways is unique and its future needs safeguarding,

Mersea Island Society Committee January 2026

The Society says that wholly insufficient attention has been given to Mersea being an island.

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

The Local Plan should reflect residents' views and seek to balance conflicting interests. It should be underpinned by ethical principles. The overriding principle should be equity, whereby all areas of the city bear a reasonable and proportionate amount of new housing. In this way, the nature and balance of the city is preserved and incrementally increased across the board. No one area should be unfairly and unreasonably adversely affected. No village community should be changed in character if it is counter to the wishes of its residents. This is an overriding qualitative judgement entrusted to councillors.

1.3 Says the Local Plan represents years of work including negotiation and co-operation from many partners and stakeholders, including local residents. St John's residents were never consulted about this, in fact it was only in late August 2025 we became aware of the Plan to include St John's fields as part of Policy PP9.
1.5 NPPF guidelines do not appear to have been followed with regard to PP9, as insufficient evidence exists that a development would be sustainable.
1.28 "The competent authority may agree to the plan or project only after having ruled out adverse effects on the integrity of the habitats site. Where an adverse effect on site integrity cannot be ruled out, and where there are no alternative solutions, the plan or project can only proceed if there are imperative reasons of over-riding public interest and if the necessary compensatory measures can be secured." Your own assessment has already identified harm to Bullock Wood SSSI from any development, so I'm unclear how you justify the inclusion of site 10256, within Policy PP9.

YOU ARE NOT ENHANCING THE ENVIRONMENT AND PEOPLES'S QUALITY OF LIFE. THESE PLANS WILL RUIN OUR SMALL VILLAGE AND THE INFRASTRUCTURE IS NOT SUITABLE FOR THIS

On the duty to co- operate that combined traffic, environmental modelling is done for the total of all proposed developments for both Colchester and adjacent planning authorities.

We raise strategic concerns regarding the structure, complexity, deliverability and policy alignment of the draft Colchester Local Plan as a whole. While the ambition of the Plan is acknowledged and supported in principle, we consider that the current draft risks being undeliverable in practice and insufficiently aligned with both market realities and the emerging national policy direction. See attachment.

Policy references
HBF would recommend that each of the paragraphs in the policies are numbered for ease of referencing. This will not only help at the examination but also for both decision makers and applicants. Paragraphs would be helpful and add to clarity for decision makers and applicants. Should the local plan be adopted.

NPPF consultation
In December 2025 the Government published a consultation on the new NPPF. HBF recognise this will have no weight until it is formally adopted but once adopted the Council may need to give weight to some aspects of the policy. On the basis of paragraph 4 and 8 in Annex A of the draft NPPF being consulted on, this local plan, which the Council propose to submit under the current plan making process, will be examined under the NPPF24. However, it is also notable that in relation to decision making Annex A also states that from the date the new NPPF is published local plan policies that are “…any way inconsistent with national decision making policies in this Framework should be given very limited weight, except where they have been exam-ined and adopted against this Framework”. Therefore, should this new iteration of the NPPF be adopted un-changed the Council may need to have regard to national policies for decision making given that any inconsistency would effectively render policies in the local plan that are not consistent with the new Framework redundant as soon as the local plan is adopted.

Duty to co-operate
Following the publication of the Housing and Planning Minister Written Ministerial Statement on the 27th of November the Government have decided not to save the Duty to Co-operate. Therefore, once the relevant regulations have been enacted Colchester will no longer be under a duty to co-operate with its neighbours. However, this does not remove the policy requirement in the NPPF to maintain effective co-operation nor the need to consider, in addition to their own housing needs, “… any needs that cannot be met within neighbour-ing areas …” as set out in paragraph 62 of the NPPF. The only difference arising from the the removal of the duty is that a failure to co-operate effectively is a soundness matter that can be rectified through main modi-fications.
6. With regard to the potential for unmet housing needs the HBF note that paragraph 2.56 of the Sustainability Appraisal states that initial discussions with neighbouring authorities progressing plans did not raise any is-sues in respect to unmet development needs, but we could find no other evidence on what co-operation has taken place – such as statements of common ground as required by paragraph 26 of the NPPF. As such it is not possible at this stage to comment on the effectiveness of any co-operation that has taken place with regard to housing or other cross boundary issues. Any co-operation must also extend beyond those neighbouring authorities at a similar stage of plan making.

Comment on Loss of Irreplaceable Farmland and Food Security
I am deeply concerned about the potential loss of Best and Most Versatile (BMV) agricultural land—particularly Grades 1 and 2—as a result of proposed allocations. This is an irreplaceable natural asset that underpins domestic food production and long‑term food security; once developed, its productive soil functions cannot realistically be restored.
The National Planning Policy Framework (NPPF, December 2024) requires plan‑makers to recognise the economic and other benefits of BMV agricultural land and, where significant development of agricultural land is necessary, to prefer poorer‑quality land. These requirements sit within the Framework’s section on conserving and enhancing the natural environment and are intended to secure sustainable outcomes that protect soils as natural capital.
Government guidance further clarifies that the planning system should protect BMV land from significant, inappropriate or unsustainable development and that decisions should be informed by the Agricultural Land Classification (ALC)—with BMV defined as Grades 1, 2 and 3a. Where land is mapped as Grade 3 but not sub‑divided, site‑specific ALC surveys are advised to confirm whether it is 3a (BMV) or 3b (non‑BMV).
Given increasing climate and geopolitical risks to supply chains, safeguarding BMV land is essential to the UK’s food resilience. The UK Food Security Report 2024 highlights the continuing importance of strong domestic production (around 62% of all food and ~75% for foods that can be grown in the UK), which depends on maintaining soil and land quality.
Requested changes to the Local Plan:
Prohibit development on Grade 1 land (no exceptions), recognising its national significance and the impossibility of like‑for‑like “compensation” for soil quality loss.
Apply a sequential approach that first exhausts brownfield, previously developed and lower‑grade (3b–5) land before any consideration of BMV, in line with the NPPF’s expectation to prefer poorer‑quality land where agricultural development is unavoidable.
Require site‑specific ALC surveys where land is graded “3 (undifferentiated)” or where mapping is uncertain, to avoid inadvertent losses of Grade 3a BMV land.
Add explicit food security wording to the policy justification, cross‑referencing the UK Food Security Report 2024 to underline the link between BMV protection, domestic supply, and climate resilience.

Introduction

1. This submission has been prepared by Cerda Planning Limited on behalf of our client in response to Colchester City Council's consultation on the Colchester Preferred Options Local Plan (Regulation 18) (November 2025) ("the Preferred Options Plan").
2. The land known as Land at Wormingford Airfield (the "Site") has been promoted through the Council's site assessment process, including the Strategic Land Availability Assessment, and through previous engagement on the emerging Local Plan. The intention of promoting the Site is to secure the allocation of the Site in the next Colchester Local Plan for a sustainable, policy-compliant and deliverable strategic mixed-use development that can contribute meaningfully to the City's housing needs, support the rural economy and assist in achieving wider strategic objectives.
3. In broad terms, the promotion seeks a comprehensive, masterplanned scheme comprising a substantial quantum of new homes (including policy-compliant affordable housing) together with the retention and planned expansion of existing employment activity and supporting infrastructure. The development concept is landscape-led, incorporating extensive green and blue infrastructure, public open space and sustainable drainage, with scope for on-site community facilities commensurate with the scale of development.
4. We welcome the opportunity to comment on the emerging Local Plan. Our representations relate specifically to Land at Wormingford Airfield, a location capable of making a significant contribution to meeting Colchester's housing requirements while also supporting employment activity and delivering infrastructure in a coordinated manner. For clarity, references to "the Site" in these representations refer to Land at Wormingford Airfield.
5. A proportionate body of technical work either accompanies, or will accompany, the promotion of the Site. This work demonstrates that the Site is capable of accommodating

sustainable development, with no constraints identified to date that would necessarily preclude its allocation or delivery within the plan period, subject to appropriate mitigation and further assessment where necessary. The detailed outputs of that work will be provided separately and are not repeated in these representations.
6. A site plan is included below, showing the employment land at Fairfields Farm within the two parcels and the surrounding built form along Fordham Road


7. This submission responds to those elements of the Preferred Options Plan most relevant to the Site and its potential role within the emerging spatial strategy. It is submitted constructively, with the aim of assisting Colchester City Council in refining and shaping the strategy and policies of the Plan so that it is positively prepared, justified, effective and consistent with national policy. In particular, these representations address:
the overall housing requirement, delivery assumptions and the need for a resilient housing supply position across the plan period, including a realistic contingency margin;
the spatial strategy and distribution of growth, including the role of strategic sites in supporting effective delivery and infrastructure provision;
the approach to site selection and the transparent testing of reasonable alternatives, including the Site; and
selected policy areas with direct implications for masterplanning, deliverability and viability, including design, infrastructure delivery, green and blue infrastructure and the rural economy.



Plan Making Context

8. The Development Plan sits at the heart of the planning system. There is a statutory requirement that planning decisions must be taken in accordance with the Development Plan unless material considerations indicate otherwise. Local Plans therefore provide the framework for future growth and development, including the scale and distribution of housing and employment, the delivery of infrastructure and community facilities, and the protection and enhancement of the natural and historic environment.
9. The National Planning Policy Framework ("the Framework") confirms this plan-led approach. Paragraph 15 states that plans should be succinct and up to date, providing a positive vision for the future and a clear framework for addressing housing needs alongside other economic, social and environmental priorities. Local plans are examined to assess legal compliance and soundness, and are considered sound when they are positively prepared, justified, effective and consistent with national policy (NPPF paragraph 36).
10. In housing terms, the Framework places significant importance on delivering a sufficient supply of homes and ensuring that a sufficient amount and variety of land can come forward where it is needed. Paragraph 61 emphasises that, to support the objective of significantly boosting the supply of homes, it is important that a sufficient amount and

variety of land can come forward where it is needed. The Framework also explains that strategic policy-making authorities should have a clear understanding of land availability through a strategic housing land availability assessment, and from this identify a sufficient supply and mix of sites taking account of availability, suitability and likely economic viability (NPPF paragraph 72).
11. The Framework recognises that the supply of large numbers of new homes can often be best achieved through planning for larger scale development. Paragraph 77 states that such schemes should be well located, well designed and supported by the necessary infrastructure and facilities, including a genuine choice of transport modes. Paragraph 77 also highlights that larger sites should demonstrate planned investment in infrastructure and scope for environmental gains; support access to services and employment opportunities; secure high quality placemaking; and deliver at a realistic rate having regard to lead-in times (NPPF paragraph 77).
12. A fundamental principle of the Framework is therefore the delivery of sustainable development through a plan-led system, including by identifying and allocating sufficient suitable sites to meet identified needs and by maintaining an up-to-date Local Plan that is deliverable in practice (NPPF paragraphs 15, 36, 61, 72 and 77).


National Planning Reform and Local Evidence Base

13. Recent and emerging national planning reforms reinforce the importance of an up-to date, plan-led system capable of delivering a significant increase in housing delivery. The Government has reiterated its ambition to deliver 1.5 million new homes in England over the course of this Parliament and has positioned planning reform as a central mechanism for achieving that objective. In that context, the direction of travel is clearly toward clearer housing requirements, a faster and more standardised plan-making process, and a stronger emphasis on implementation and delivery so that plan allocations translate into completed homes at pace.
14. Alongside reforms to national policy, the Government has introduced a package of measures intended to unlock and accelerate delivery. This includes the New Homes Accelerator, first announced in July 2024, which is specifically framed as a mechanism to speed up delivery of large-scale housing developments and support the wider 1.5 million homes ambition. It also includes a programme of consultations and technical proposals aimed at improving the efficiency, transparency and governance of the planning system. By way of example, the Government consulted in 2025 on reform of

planning committees, including proposals relating to delegation, committee size and composition, and mandatory member training, all directed at streamlining decision making and improving consistency.
15. The Government has also brought forward the Planning and Infrastructure Bill, supported by a wider policy narrative that seeks to speed up and streamline the delivery of new homes and critical infrastructure, including by addressing barriers that slow housing delivery and infrastructure consenting. The importance of this agenda for plan making is that it reinforces the expectation that Local Plans should be deliverable and infrastructure-aware. It also underlines the need for allocations to be supported by credible infrastructure planning and realistic delivery assumptions, rather than relying on aspirational trajectories that cannot be implemented in practice.
16. A further central component of the reforms is the move to a faster plan-making process. Government guidance published in late 2025 sets out the expectation that local planning authorities should prepare a single local plan and adopt it within a 30-month process under the reformed system. That change is intended to accelerate plan coverage and reduce the time lag between evidence, strategy selection and adopted policy. In parallel, reforms flowing from the Levelling-up and Regeneration Act 2023 include the intention to move away from the existing Duty to Cooperate model within the reformed plan making system. The clear direction is toward a more outcome-focused approach to strategic alignment that seeks to reduce delay while still requiring effective engagement on cross-boundary matters in practice.
17. National planning reform has also been accompanied by a renewed emphasis on strategic new settlement delivery. In September 2025, the Government published the New Towns Taskforce report and separately announced that an expert taskforce had recommended locations for new towns, with an emphasis on large-scale delivery and a clear expectation that such proposals contribute materially to national housing supply. In that context, Tempsford has been identified as one of the priority locations linked to the strategic benefits of planned rail infrastructure. While that specific growth corridor is not determinative for Colchester, it is indicative of the Government's approach: planning and economic growth are central, strategic locations are being advanced, and plan making is expected to facilitate delivery at scale.
18. These reforms underline that up-to-date Local Plans are intended to be the primary mechanism for delivering housing, employment and infrastructure objectives. They also reinforce the continuing relevance of the National Planning Policy Framework ("the Framework") plan-led and delivery-led principles. In particular, NPPF paragraph 15

expects plans to provide a clear framework for addressing housing needs alongside other priorities, and paragraph 36 confirms that plans will be examined for soundness, including whether they are positively prepared and effective. The national emphasis on ensuring that a sufficient amount and variety of land can come forward where it is needed, supported by a clear understanding of land availability, also remains central (NPPF paragraphs 61 and 72). In plan-making terms, those principles point toward the need for a deliverable strategy supported by a balanced portfolio of sites and a realistic contingency margin, so that the housing requirement can be met even where some components deliver later than anticipated.
19. Against that national context, it is particularly important that Colchester City Council's Preferred Options Local Plan is robust and deliverable, with a clear route to maintaining an adequate housing land supply throughout the plan period. Delivery risk inevitably arises over long plan periods due to market cycles, infrastructure dependencies, lead-in times and scheme-specific constraints. National reforms that focus on implementation and build-out transparency heighten the importance of being realistic at plan stage. A plan that depends on a narrow range of supply sources or optimistic assumptions is more exposed to slippage. Conversely, a plan supported by a balanced and diverse portfolio of sites, including strategic opportunities capable of comprehensive delivery and infrastructure provision, is more resilient and better aligned with the Government's delivery objectives.
20. Colchester City Council has prepared and published a substantial evidence base to support the Preferred Options Plan. This includes evidence relating to settlement roles and the settlement hierarchy (including the Council's Settlement Evidence work), site availability and suitability (through the SLAA process), infrastructure capacity and delivery planning (through the Infrastructure Audit and Delivery Plan), landscape character and sensitivity, open space and green infrastructure needs, economic and employment needs, and whole-plan viability. The breadth of this evidence provides an appropriate basis at Regulation 18 stage for decisions on the scale and distribution of growth and for the transparent testing of reasonable alternatives.
21. While strands of the evidence base will inevitably be refined as the Plan progresses toward submission, particularly in relation to infrastructure delivery programming, viability inputs and the delivery trajectory, that does not diminish the need at this stage for a strategy that is demonstrably deliverable and resilient. The purpose of Regulation 18 is to test the emerging strategy and options, including whether there is sufficient flexibility and contingency in the supply portfolio. In that context, it is essential that the

Preferred Options Plan makes effective use of the evidence base when determining both the quantum and the location of development, including through clear and transparent reporting of site assessment outcomes and reasonable alternatives testing.
22. Against this policy and evidence backdrop, the representations that follow are submitted constructively to assist Colchester City Council in aligning the emerging spatial strategy and site selection with national policy and the local evidence base. In particular, they are intended to demonstrate how Land at Wormingford Airfield can contribute to the Plan's delivery objectives through a strategic mixed-use proposition that supports both housing delivery and the rural economy, including through the retention and expansion of established employment activity, whilst being shaped through masterplanning and mitigation to respond appropriately to the countryside and sustainability considerations identified in the Council's evidence base.



Site Context
Land at Wormingford Airfield (Fairfields Farm, SLAA Site ID 10638)

23. The Site is located at Wormingford Airfield (Fordham Road, Colchester, CO6 3AQ) within the administrative area of Colchester City Council and is promoted through the Council's Call for Sites and SLAA process (recorded as "Fairfields Farm Wormingford Airfield", Site ID 10638).
24. The Site forms part of the wider Wormingford Airfield land and includes a residential-led parcel promoted by our client, land intended to be retained for employment purposes and the existing employment land associated with Fairfields and Fairfield Crisps. The combined landholding across these parcels extends to approximately 54 hectares.
25. In locational terms, the Site lies in open countryside outside any defined settlement boundary and is not immediately contiguous with an identified settlement. Wormingford village lies in the vicinity, and Colchester is the principal urban centre to which the Site relates in strategic terms. The B1508 lies to the east and provides a strategic north to south route between Colchester and Sudbury. The A12 lies to the south, with access to the strategic road network available via the Marks Tey junctions.
26. The Site has frontage to Fordham Road and also relates to Mount Bures Road. There are existing vehicle access points from Fordham Road associated with current uses, including accesses serving the Gliding Club and the existing operational land. The Essex and Suffolk Gliding Club operates from part of the wider airfield land.

27. A further characteristic of the Site is the presence of public rights of way and bridleways within and adjacent to the wider airfield land, which provides a strong basis for a connected green infrastructure and movement network.
28. The transport evidence prepared as part of earlier due diligence identifies Fordham Road as the appropriate focus for any future principal site access arrangements. It also identifies that the surrounding "Protected Lanes" network is narrow and is not suited to accommodating significant additional vehicular movements, although it offers opportunities for enhanced walking and cycling connectivity. Notwithstanding the rural context, the Site sits within reach of existing and potential sustainable movement corridors. National Cycle Network Route 13 runs in the vicinity and provides onward connections towards Colchester and to nearby settlements. Existing bus services operate in the wider area, including services connecting Wormingford, Colchester and Sudbury. The evidence base also recognises that the opportunities for non-car travel will need to be strengthened through development-led measures, including improved walking and cycling infrastructure and potential enhancements to public transport provision.
29. The Site is promoted as a strategic mixed-use development opportunity capable of contributing to both housing and economic objectives. A distinguishing feature is the presence of an established and expanding local employer, with clear aspirations for growth and continued investment, and a requirement to retain operational continuity. The Site therefore presents an opportunity, in principle, to align planned housing growth with the retention and expansion of employment activity through a coordinated, masterplanned approach, rather than relying on piecemeal development in the countryside.
30. In terms of form and content, and subject to masterplanning and technical assessment, the Site is capable of supporting a strategic mixed-use scheme at a scale which could, in principle, include a substantial residential component (potentially in the order of circa 600 dwellings), alongside retained and enhanced employment land and supporting infrastructure. The development concept could theoretically comprise policy compliant affordable housing, community facilities appropriate to the scale of development, education provision where justified, and a comprehensive green infrastructure and sustainable drainage network, with public access and connectivity enhanced through the existing rights of way and bridleway network.
31. The Site is therefore well placed to make a meaningful contribution to the next Colchester Local Plan as an allocation, particularly where the Council must ensure that

the spatial strategy is deliverable, sufficiently flexible and capable of maintaining an effective housing supply position, including a realistic contingency margin, while also supporting local economic objectives. The following sections of these representations build on this site description by addressing the relevant strategic and development management policies and by setting out the case for the Site to be included as a proposed allocation within the emerging Plan.


Spatial Strategy and Development in the Countryside
Preferred Options Draft Policies ST3 and ST4

32. Policies ST3 (Spatial Strategy) and ST4 (Development in the Countryside) establish the Plan's approach to distributing growth to 2041, including how the settlement hierarchy is used, how countryside impacts are managed, and how development is balanced against biodiversity, landscape and heritage considerations.
33. We support the Council's overarching direction of focusing growth in the most sustainable locations. This reflects the plan-led approach in NPPF paragraph 15, which expects plans to provide a clear framework for meeting housing needs alongside other priorities, and the soundness framework in NPPF paragraph 36, which requires the Plan to be positively prepared and effective. It also aligns with the Council's Settlement Evidence, which explains that growth is directed first to the urban area and locations close to transport corridors and centres, with growth elsewhere informed by opportunities and constraints.
34. However, to be effective in delivery terms, the spatial strategy must also provide sufficient flexibility to manage delivery risk and maintain an effective housing supply position over the plan period. This is consistent with NPPF paragraph 61, which emphasises the importance of ensuring that a sufficient amount and variety of land can come forward where it is needed, and NPPF paragraph 72, which expects plans to identify a sufficient supply and mix of sites having regard to availability, suitability and likely viability. In that context, the Council's application of ST3 and ST4 should not operate in a way that inadvertently narrows the allocations portfolio to the point that delivery resilience is weakened.

Policy ST3: Spatial Strategy

35. ST3 confirms that growth is primarily focused on the settlement hierarchy, having regard to sustainability merits, size, function and services, balanced against biodiversity, landscape and heritage. ST3 also supports previously developed land and higher densities where they enable efficient use of land.
36. We support these principles, but the way ST3 is drafted and applied should make clear that the settlement hierarchy is a guiding framework rather than an absolute constraint on strategic allocations. This is important for two related reasons.
37. First, NPPF paragraph 77 recognises that the supply of large numbers of new homes can often be best achieved through larger scale development, provided schemes are well located, well designed and supported by necessary infrastructure and facilities, including a genuine choice of transport modes. That national policy approach anticipates that plans will identify strategic opportunities where, in principle, infrastructure and environmental gains can be planned and secured comprehensively, and where delivery can be sustained over time. It therefore reinforces the need for ST3 to be capable of accommodating strategic allocations where they strengthen plan effectiveness and delivery resilience.
38. Second, the Council's own evidence recognises that growth patterns can legitimately be shaped by factors beyond a simple proportional distribution through the hierarchy, including transport corridors, infrastructure considerations and the ability to deliver community benefits. The spatial strategy should therefore be applied in a way that allows the Council to test and, where justified, select strategic sites that may sit outside existing settlement boundaries but can contribute materially to housing delivery, infrastructure provision and economic objectives.
39. In practical terms, that means the Council should ensure that Land at Wormingford Airfield is assessed transparently as a reasonable alternative through the site selection process and Sustainability Appraisal, noting that it is already included within the assessed site pool as "Fairfields Farm Wormingford Airfield" (SLAA Site ID 10638). The Site is promoted as a strategic mixed-use opportunity linked to established employment activity and the rural economy, and it should be assessed on that basis rather than filtered out by reference to countryside location alone.

Policy ST4: Development in the Countryside

40. ST4 confirms that development in the countryside will be considered where required to meet identified needs in accordance with the spatial strategy, while supporting the vitality of rural communities. It also seeks to avoid adverse impacts on settlement roles and identities, valued landscapes and the intrinsic character and beauty of the countryside, and it recognises the importance of access to sustainable modes of travel. ST4 also supports sustainable rural businesses where criteria are met.
41. We support the intent of ST4 and agree that countryside restraint and landscape protection must remain central. The Council's settlement evidence is clear that areas outside settlement boundaries are countryside and that boundaries perform an important management role in directing growth and protecting rural character.
42. The key issue is how ST4 is applied in plan-making terms. ST4 is expressly drafted to allow countryside development where required to meet identified needs. It should therefore function as a criteria-based framework for shaping development, securing mitigation and protecting assets, rather than operating as a policy barrier that precludes strategic allocations in countryside locations even where the evidence supports them and where allocation is necessary to maintain deliverability and resilience.
43. This is directly relevant to Wormingford Airfield. The Council's Settlement Evidence Stage 1 identifies Wormingford as a small settlement with limited services and facilities and limited public transport accessibility. We recognise and accept that baseline. It means that any strategic allocation at Wormingford Airfield must be advanced on a mitigation-led, masterplanned basis and should not be justified by overstating the existing service role of the village.
44. However, that baseline does not remove the plan-making question that ST4 itself raises, which is whether there are strategic countryside locations that can meet identified needs through comprehensive planning and mitigation, including by providing supporting facilities, improving sustainable movement opportunities and delivering environmental enhancement. Earlier transport due diligence for the land identifies limitations in walkable destinations and constraints in the rural road environment, but it also identifies existing access opportunities from Fordham Road, the role of the rights of way network, and the existence of longer-distance cycling connectivity in the vicinity. Those factors point to the appropriate approach for any allocation here. If the Site is taken forward, the Plan should require a package of measures which could theoretically include enhanced pedestrian and cycle links, improvements to public transport provision, and on-site

facilities commensurate with the scale of development, alongside landscape-led design and phasing.
45. That approach is consistent with the effectiveness test in NPPF paragraph 36 and with the requirement in NPPF paragraph 72 to identify sites having regard to deliverability, suitability and likely viability. It also aligns with the Council's infrastructure planning approach as set out in its infrastructure audit and delivery work.
46. Taken together, the application of ST3 and ST4 should therefore lead the Council to test Wormingford Airfield transparently through the evidence base and Sustainability Appraisal, and where the assessment demonstrates that impacts can be mitigated and the site can deliver in a comprehensive way, to progress it as an allocation in the next Local Plan. That outcome would strengthen the Plan's resilience, provide additional flexibility in the supply portfolio and support economic objectives through the retention and expansion of existing employment activity, while still operating within the countryside protection framework provided by ST4.



Housing Needs and Delivery
Draft Policy ST5, Local Housing Need, five-year housing land supply and delivery assumptions
47. Draft Policy ST5 sits at the core of the Preferred Options Plan, as it translates the Council's housing evidence into a quantified requirement and, critically, into a deliverable strategy. This approach aligns with the National Planning Policy Framework (December 2024) which requires strategic policies to meet identified needs (paragraph 11) and to identify and maintain a sufficient supply and mix of sites (paragraphs 72 and 78).
48. The Council's evidence base identifies a local housing need figure of 1,300 dwellings per annum, described as a mandatory target for the purposes of the Plan. This is an important anchor for ST5, particularly in the context of the Government's stated objective of materially boosting delivery and the policy direction towards clearer requirements, more streamlined plan-making and a stronger focus on implementation and delivery.
49. It is also notable that the Habitats Regulations Assessment supporting the Preferred Options stage identifies, an overall requirement of 21,106 dwellings (2025 to 2041) and a claimed supply position of 23,202 dwellings, including commitments, a windfall allowance and proposed allocations. In principle, we support the Council's intention to plan positively for housing by identifying a portfolio that exceeds the minimum

requirement, as this is consistent with the need for plans to be effective and deliverable in practice, not simply theoretically compliant.
50. However, the key issue for ST5 is not whether the Plan can present a headline surplus at a single point in time, but whether the strategy is underpinned by delivery assumptions that are realistic and resilient to foreseeable delivery risks. The NPPF is explicit that authorities should make a realistic assessment of delivery rates for large scale development (paragraph 77) and should maintain supply through an annually updated stock of deliverable sites with the appropriate buffer (paragraph 78).
51. In delivery terms, the most recent published Housing Delivery Test measurement (2023) indicates that Colchester delivered 110% of its requirement over the relevant three-year period, with no associated consequence. This is a positive position in national monitoring terms and indicates that the Council is not currently subject to the more stringent policy consequences that apply where delivery falls below 95%, 85% or 75% (NPPF paragraph 79).
52. Nevertheless, the HOT result should not be interpreted as removing the need for a robust, risk-aware ST5 strategy. The Preferred Options Plan period extends to 2041, and delivery risk over that timeframe is inevitable due to market cycles, infrastructure dependencies, lead-in times, labour and materials constraints, and the practical realities of phased build-out. The Government's wider reform agenda is increasingly focused on transparency and implementation, reinforcing that plans must not only allocate land, but also demonstrate credible pathways to delivery at pace and scale.
53. In that context, we support the principle that ST5 should be applied alongside a realistic contingency margin and a balanced portfolio of sites. This is consistent with the function of the NPPF buffer, which is intended to ensure choice and competition and to improve the prospect of achieving planned supply (NPPF paragraph 78). The corollary is that any apparent "surplus" in the overall supply should be treated, in practical plan-making terms, as a necessary allowance for slippage rather than a justification to exclude otherwise suitable and deliverable sites.
54. The Council's five-year housing land supply evidence provides an important lens on delivery assumptions. The Council's published 2025 Housing Land Supply Position Statement (base date 1 April 2025) explains that, for five-year supply purposes, Colchester has historically calculated its requirement using the adopted Local Plan annual requirement of 920 dwellings per annum and applies a 5% buffer. The statement also records that the Council did not publish a 2024 position statement, relying on the

NPPF provisions that apply where an adopted plan is less than five years old and identified a five-year supply at examination.
55. While the five-year supply position is a distinct monitoring exercise, its assumptions are directly relevant to ST5 in two respects. First, ST5 is proposing a materially higher annual requirement anchored to the Council's evidence base (1,300 dwellings per annum), and therefore the Plan's delivery framework needs to be calibrated to that higher delivery challenge rather than to the historic adopted requirement. Secondly, the Council's approach to deliverability, lead-in times and build-out trajectories across its supply should be transparent and internally consistent between the Plan's overall trajectory and the methodology used in its monitoring statements, in order to demonstrate that ST5 is effective and not reliant on optimistic assumptions.
56. Similarly, where the Council relies on components such as windfall in its overall supply position, the NPPF requires "compelling evidence" that windfalls will provide a reliable source of supply, and that any allowance is realistic in the context of the housing land availability assessment and historic delivery. (NPPF paragraph 75). In our view, ST5 should be supported by a clear and proportionate explanation of how any windfall allowance has been derived and why it remains robust under the higher LHN-led requirement, particularly given the emphasis in national policy and reform discourse on delivery realism.
57. Against that background, there is a strong plan-making case for ensuring that ST5 is supported by additional allocations that are capable of contributing to housing delivery and that also align with the Plan's wider objectives. This includes allocations that can provide a meaningful quantum of housing, but also those that can contribute to employment, rural services and the wider sustainability outcomes sought by the Plan. This is consistent with the NPPF's recognition that large scale development can best achieve significant supply, provided it is well located and supported by infrastructure and a realistic rate of delivery (paragraph 77).
58. Land at Wormingford Airfield is relevant in these terms. The Site is promoted as a strategic mixed-use opportunity which, in principle, is capable of making a material contribution to housing delivery over the plan period, potentially including circa 600 dwellings, alongside the retention and expansion of employment activity and the delivery of on-site infrastructure and environmental gains. The promotion is not advanced as a commitment to a fixed quantum or a fixed delivery programme. Rather, it is advanced as a credible allocation option that can contribute to the resilience of the Plan's housing

supply and the effective delivery of ST5, including by providing additional choice within the portfolio and a practical contingency against slippage elsewhere.
59. Importantly, this is not an argument for dispersing growth irrespective of sustainability considerations. As noted elsewhere in these representations, Wormingford is a smaller settlement and therefore the planning balance must be approached carefully. The point for ST5 is that the Plan should not inadvertently increase delivery risk by relying disproportionately on a narrower set of sites, particularly where delivery is contingent on complex infrastructure interventions or long lead-in times. A balanced portfolio that includes deliverable, well-planned strategic opportunities is more likely to maintain delivery over the plan period and to avoid destabilising under-delivery scenarios that would frustrate both local objectives and the Government's broader housing ambitions.
60. For the purposes of improving the effectiveness of ST5 and its supporting trajectory, we therefore recommend that the Council:
demonstrates, transparently, how delivery rates and lead-in assumptions have been derived for proposed allocations, consistent with NPPF paragraph 77;
evidences any windfall allowance against the NPPF test of compelling evidence (paragraph 75), particularly in the context of the higher LHN-led requirement;
ensures that the Plan's supply surplus is treated as a realistic contingency margin, rather than as a margin that can safely be eroded through the exclusion of otherwise suitable allocations; and
includes additional deliverable allocations, such as Land at Wormingford Airfield, to strengthen the robustness of the housing delivery strategy and reduce plan risk over a long plan period.
61. On this basis, we support the direction of Draft Policy ST5 in anchoring the Plan's housing requirement to the Council's evidence. However, we consider that ST5 will only be demonstrably sound if it is underpinned by a delivery strategy that is explicit about its assumptions, realistic about delivery risk, and supported by a sufficiently diverse and resilient portfolio of allocations. Land at Wormingford Airfield can assist in that regard by providing an additional strategic allocation option capable of contributing to both housing delivery and wider plan objectives over the plan period.

Tendring Colchester Borders Garden Community
Draft Policy ST9 and the Garden Community DPD

62. Draft Policy ST9 addresses the Tendring Colchester Borders Garden Community ("TCBGC") and confirms that proposals within the development boundary will be determined in line with the policies and requirements set out in the Garden Community Development Plan Document ("DPD"). ST9 also reflects the relationship with the saved strategic policies for the Garden Community (SP8 and SP9) which continue to apply where relevant.
63. The inclusion of the Garden Community as a strategic component of the housing strategy is clearly significant in quantitative and delivery terms. The Council's own housing supply presentation, as set out in its viability evidence policies matrix, includes an assumed contribution of 1,700 dwellings from the TCBGC within the plan period. As a result, the effectiveness of ST5 and the overall supply position is sensitive to the timing and certainty of delivery from this strategic element.
64. While a DPD-led approach can provide an appropriate policy framework for a complex strategic site, the plan-making issue is whether ST9 and the wider evidence demonstrate sufficient confidence in timely delivery to justify the scale and phasing of the assumed contribution within the plan period. Strategic new settlement delivery is inherently complex and is often characterised by long lead-in times and dependence on infrastructure sequencing, delivery mechanisms and market absorption. These are matters of practical implementation, which national planning reform is increasingly seeking to address through greater emphasis on delivery realism and build-out performance.
65. The Council's Infrastructure Audit and Delivery Plan ("IADP") confirms the significance of the Garden Community and its infrastructure requirements. It also reinforces that delivery is dependent on a substantial package of infrastructure and on an effective programme for implementation and phasing. This is relevant because where a plan relies materially on such a strategic component, it must also demonstrate appropriate flexibility in the remainder of the allocations portfolio to manage inevitable delivery risk.
66. In this regard, appeal decision-making has previously highlighted the uncertainties that can arise where delivery assumptions depend on strategic components. The Inspector's decision in the Tiptree appeal (ref: APP/A1530/W/22/3301862) noted disputes regarding the timing and certainty of the Garden Community contribution, including that delivery was dependent on a DPD framework and that slippage and uncertainty were material considerations at that time. Although the plan-making context has evolved since, the

appeal illustrates the broader point that reliance on strategic components can be subject to challenge where delivery assumptions are not demonstrably robust.
67. These considerations are important for the Preferred Options Plan because the Plan period is lengthy and delivery risk is unavoidable. The Council is seeking to plan positively to meet a higher local housing need figure, and the Plan's effectiveness will depend on whether housing is delivered consistently through the period rather than backloaded. Where a material component of supply is dependent on strategic infrastructure-led delivery, it is prudent for the Plan to include sufficient additional allocations elsewhere to provide a realistic contingency margin and avoid under-delivery if strategic outputs are delayed.
68. In this context, ST9 should be framed and applied in a way that does not inadvertently place too much weight on optimistic assumptions regarding early or mid-plan delivery from the Garden Community. Instead, ST9 should sit within a wider strategy that recognises the delivery characteristics of strategic new settlement growth and therefore provides a sufficiently broad and diverse portfolio of allocations to ensure that the housing requirement can be met over the plan period.
69. This is directly relevant to the case for additional allocations such as Land at Wormingford Airfield. The Site is not promoted as an alternative to the Garden Community, but as a complementary strategic option that can strengthen the robustness of the overall housing delivery strategy. It is a known site within the Council's assessed pool, and it is promoted as a strategic mixed-use opportunity capable in principle of contributing to housing delivery alongside economic objectives.
70. The key plan-making point is therefore that, if the Garden Community is relied upon materially within the plan period, the Preferred Options Plan should demonstrate clear evidence and transparency on the timing and phasing assumptions for that contribution, and it should include additional allocations capable of coming forward in parallel so that housing needs are met even in scenarios of delay or slower build-out. This approach is consistent with the Government's reform agenda, which is increasingly focused on ensuring that plan allocations are translated into delivery, and with national policy expectations that plans should be effective and deliverable in practice.
71. On that basis, ST9 should be treated as a strategic component that requires careful monitoring and realistic programming, and the Plan's allocations portfolio should be strengthened so that the housing strategy is resilient to slippage in delivery from the Garden Community. The allocation of additional deliverable sites, including Land at

Wormingford Airfield, would assist in maintaining a realistic contingency margin and ensuring housing needs can be met across the plan period.


Environment and Green Network and Waterways
Draft Strategic Policy ST2 and related Green Network and Environment policies (GN1, GN2, EN1-EN3)
72. We support the intention of Draft Policy ST2 to ensure that growth conserves and enhances Colchester's natural and historic environment and safeguards landscape character through an integrated approach to biodiversity, green network and waterways, and heritage. This is aligned with national policy, which requires plans and decisions to contribute to and enhance the natural and local environment and, where relevant, to give particular weight to conserving and enhancing landscapes designated for their scenic beauty, including their setting (NPPF December 2024, including paragraphs 187- 190).
73. However, for the purposes of plan-making and site selection, it is important that ST2 is applied in a way that is both evidence-led and delivery-focused. Colchester's own settlements evidence is explicit that enhancing the green network and waterways is a "key starting point" for the Plan and that new allocations can be prioritised where there is clear opportunity to deliver environmental enhancements alongside growth. In that context, the Site at Wormingford Airfield should be assessed not simply through the lens of constraint, but also through its capacity to deliver measurable environmental gains through comprehensive masterplanning, including landscape-led structure, habitat creation, and green and blue infrastructure that improves connectivity and addresses local deficits.
74. We support the principle of Policy GN1, including the requirement for major residential development to submit a Green Network and Waterways Plan and to incorporate multifunctional open space of at least 10% of gross site area, designed around SuDS and climate adaptation and supported by long-term management arrangements. These are appropriate expectations for strategic allocations. The key point for the Preferred Options Plan is that the policy framework and allocation approach should actively enable strategic sites to plan positively for these outcomes, rather than treating them as residual requirements to be "fitted in" later. In practical terms, where a strategic site is expected to deliver substantial green and blue infrastructure, the allocation policy should clearly signpost the intended green network role of the site, the broad location of strategic open

space, and the requirements for long-term stewardship, so that deliverability, land budgeting and viability are transparently addressed at plan stage.
75. Policy GN2's emphasis on delivering strategic green spaces, habitat creation and nature recovery aligned with the Essex Local Nature Recovery Strategy is also supported. For Wormingford Airfield, this is directly relevant: a masterplanned approach can use green and blue infrastructure as the organising framework for the scheme, securing habitat connectivity, SuDS-led water management and accessible open space in a way that contributes to wider ecological networks. This also aligns with the Council's infrastructure evidence, which sets out green infrastructure guiding principles focused on multifunctionality, connectivity, character, and long-term management.
76. We also support the intent of Policy EN1 in relation to designated nature conservation sites and the requirement for avoidance and mitigation where recreational impacts arise, including through the Essex Coast RAMS (Bird Aware Essex Coast) mechanisms. From a plan-making perspective, the important point is to ensure that the Preferred Options Plan does not inadvertently over-rely on a small number of strategic allocations while assuming that project-level mitigation will resolve cumulative effects. The more resilient approach is to allocate a balanced portfolio of deliverable sites, each capable of embedding green and blue infrastructure from the outset, with clear policy hooks for proportionate avoidance and mitigation (including any project-level on-site greenspace measures where relevant) alongside the strategic RAMS framework.
77. Policy EN2 and EN3 are similarly supported in principle. The requirement to deliver at least 10% biodiversity net gain and to maximise on-site delivery is now a central component of effective and credible plan-making, and the policy correctly links delivery to evidence and the mitigation hierarchy. For Wormingford Airfield, this is a further reason to pursue allocation: strategic sites can deliver BNG in a planned, coherent way, integrated with open space, SuDS and landscape buffers, rather than through fragmented or piecemeal approaches. In addition, the Council's whole-plan viability work explicitly recognises that policies such as GN1 and EN2 have viability implications which need to be reflected through appropriate assumptions at plan stage. This reinforces the value of bringing forward strategic allocations that can internalise these requirements through masterplanning and land budgeting, rather than relying on smaller sites where policy compliance can be harder to reconcile with delivery.
78. Overall, the environmental and green network policies are capable of supporting a sound strategy, but their effectiveness will depend on how they are translated into the allocations and trajectory. If the Council is seeking to embed a genuinely plan-led green

network and waterways approach, it should ensure that the Preferred Options Plan allocates additional deliverable strategic sites that can demonstrably deliver multifunctional open space, nature recovery and landscape-led design at scale. In our view, Wormingford Airfield is well suited to that role and should be taken forward as an allocation, supported by an appropriately framed allocation policy that secures environmental outcomes through masterplanning without introducing undue prescription that could hinder timely delivery.


Rural Workers' Dwellings
Preferred Options Draft Policy HB

79. Policy H8 (Rural Workers' Dwellings) is an important policy in the context of Colchester's rural economy. It provides the criteria framework through which on-site accommodation can be supported where there is an essential functional need linked to a rural-based business, including tests around viability of the enterprise, alternative accommodation, design and landscape integration and flood risk.
80. The relevance of H8 to these representations is twofold. First, it provides an appropriate policy mechanism for supporting rural enterprises where on-site accommodation is genuinely necessary to sustain operations, which aligns with national policy's objective of supporting a prosperous rural economy and the vitality of rural communities. Secondly, it is important that H8 is applied in a way that is coherent with the Plan's wider strategy of supporting employment and mixed-use delivery, including in locations where established rural employment activity is to be retained and expanded.
81. In that context, Land at Wormingford Airfield is promoted as a strategic mixed-use opportunity which includes the retention and planned expansion of existing employment activity. The Plan should avoid a position where the operational needs of a rural-based business within a strategic allocation are inadvertently frustrated by an overly narrow interpretation of H8, particularly where masterplanning can address siting, design and landscape integration in a coordinated manner. This is not an argument that any on-site accommodation is required or proposed at this stage. Rather, it is an allocation-stage point that the policy framework should be capable of supporting the practical operation and planned growth of rural employment uses where robust evidence demonstrates an essential functional need.
82. We therefore support H8 in principle, but recommend that the supporting text clarifies two matters for effective implementation:

Relationship with strategic allocations and masterplanning: where a strategic site allocation includes the retention and expansion of rural employment activity, any proposal for a rural workers' dwelling should be capable of being considered in the context of an agreed masterplan and parameter framework, so that the policy tests on siting, landscape integration and amenity can be addressed comprehensively rather than in isolation. This would support coordinated delivery and avoid piecemeal decision-making.
Proportionate application of the "temporary dwelling" expectation: H8 includes a criterion referencing circumstances where a temporary rural workers' dwelling has previously been granted, or evidence is provided to justify why a temporary dwelling has not been required. It would assist clarity if the Plan confirms that this is not a rigid sequencing requirement, and that where a business is demonstrably established and evidence shows an essential functional need, the policy allows an appropriately evidenced route to a permanent dwelling without unnecessary delay.
83. These clarifications would strengthen policy effectiveness, align H8 more clearly with the Plan's economic strategy, and ensure that the Plan supports genuine rural enterprise needs without weakening the safeguards that the criteria provide.


Economy
Preferred Options Draft Policies E1, E2 and E3

84. The economy policy suite is a material part of the Site promotion case because Land at Wormingford Airfield is advanced as a strategic mixed-use opportunity, including the retention and planned expansion of existing employment activity alongside new homes. In plan-making terms, this is relevant to the soundness and effectiveness of the Preferred Options Plan because it can assist in achieving a more balanced relationship between homes and jobs, and it provides a practical mechanism for supporting the rural economy as part of an allocation-led approach.
85. Policy E1 (Protection of Employment) safeguards existing employment land and premises (including identified employment provision) primarily for Class E(g), B2 and B8 uses, and only supports redevelopment or change to non-employment uses where a series of tests are met, including no reasonable prospect of continued employment use supported by at least 12 months marketing evidence. In principle, we support the

objective of protecting fit-for-purpose employment provision and avoiding unnecessary loss of employment land.
86. However, it is important that E1 is applied with sufficient flexibility to support the Plan's wider objectives, particularly where strategic sites come forward as comprehensive, masterplanned proposals. The Council's Employment Study identifies an overall quantitative shortfall in employment land supply relative to forecast demand over the plan period and recommends that the Council will need to identify additional sites, while also adopting a balanced approach to protection to avoid both "over-protection" and "under-protection". The Study also highlights the need to support a range of business sizes and requirements and acknowledges that demand and suitability will vary geographically.
87. In that context, the key point for this Site promotion is that E1 should not be applied in a way that inadvertently discourages comprehensive mixed-use schemes that retain and support employment activity. E1 includes a criterion seeking to avoid conflict with existing or proposed B or E(g) uses, including in relation to traffic, noise and other effects.
88. For strategic mixed-use allocations, the correct plan-led response is not to treat potential interface issues as a reason to exclude sites at plan stage, but to ensure that allocation policy and masterplanning secure appropriate design, buffers, access and phasing so that employment activity can operate successfully alongside new homes. This is one of the principal advantages of allocation, as it enables coordinated mitigation rather than piecemeal decision-making.
89. Policy E2 (Economic Development in Rural Areas and the Countryside) is directly relevant to Wormingford Airfield. E2 confirms that the Council will protect employment areas in rural Colchester that provide an economic function, including both allocated sites and other rural locations performing a similar role, and identifies a range of employment-generating uses that are appropriate in principle, including E(g), B2 and B8 uses and other employment-generating activities aligned with rural enterprise. E2 also supports extensions and replacement buildings where they are beneficial to an established business, subject to appropriate design and landscape mitigation.
90. This policy direction strongly reinforces the planning logic of allocating Wormingford Airfield as a strategic mixed-use site. Rather than treating the existing employment function as a constraint on housing allocation, E2 provides a positive policy basis to retain and strengthen rural employment uses, including through appropriate enhancement and modernisation of premises, while controlling environmental effects. It

is also consistent with the Council's Employment Study recommendations that the Council should support flexibility in the rural economy, including opportunities to reuse and adapt land and buildings where appropriate.
91. For policy effectiveness, it would assist if the supporting text for E2 (and the application of E1 where relevant) is clear that the "rural employment" protection framework is intended to support investment and planned growth of established rural employment activities, including where those activities sit within a strategic mixed-use allocation. This matters for deliverability: where the Plan seeks to combine housing delivery with employment retention and growth, the policy framework should be unambiguous that coordinated masterplanning is the means by which amenity and landscape matters will be managed, rather than an approach that inadvertently sterilises the employment component or deters investment through uncertainty.
92. Policy E3 (Agricultural Development and Diversification) is also relevant in principle, as it supports and encourages appropriate diversification proposals that sustain rural enterprise, subject to compatibility with the rural environment and other policy protections. While Wormingford Airfield is not promoted as an agricultural diversification scheme, the policy reinforces the Plan's wider objective of sustaining rural economic activity and supporting enterprise in the countryside, which is aligned with the Site's mixed-use promotion and the retention and expansion of existing employment activity.
93. Overall, the economy policy suite supports, rather than undermines, the case for taking Wormingford Airfield forward as an allocation option. In particular, E2 provides a strong policy basis for safeguarding and enhancing rural employment functions, and the Council's Employment Study indicates that the Plan must ensure sufficient employment land and adopt a balanced approach that avoids blight and supports investment. We therefore request that, as the Plan progresses, the Council ensures that:
the application of E1 and E2 explicitly supports comprehensive, masterplanned mixed-use allocations that retain and strengthen established rural employment activity; and
the site selection and reasonable alternatives testing gives positive weight to strategic sites that can support both housing delivery and the rural economy, subject to criteria-led allocation requirements on access, design, landscape mitigation and amenity protection.

Growth and Opportunity Areas and Proposed Allocations
Strategic approach to allocations and the case for Land at Wormingford Airfield

94. The Growth and Opportunity Areas and Proposed Allocations component of the Preferred Options Plan is the point at which the Council translates the spatial strategy, housing requirement and evidence base into a deliverable portfolio of sites. This is therefore the principal mechanism for ensuring the Plan is effective and capable of meeting Colchester's housing needs over the plan period, consistent with national policy expectations that plans identify a sufficient supply and mix of sites, supported by realistic delivery assumptions. It is also the stage at which the Council must transparently test reasonable alternatives through the Sustainability Appraisal and site selection process, so that allocations are justified and robust.
95. The Plan's housing requirement is framed at a materially higher level than the adopted Local Plan requirement. As set out earlier in these representations, the Preferred Options housing requirement is based on a local housing need figure of around 1,300 dwellings per annum, while the Council's most recent published five-year housing land supply position statement is calculated using the historic adopted annual requirement of 920 dwellings per annum. This internal alignment point matters directly for allocations: the portfolio and trajectory must be capable of supporting a higher delivery challenge, and the Plan should not rely on narrow margins or optimistic assumptions that are only sufficient when measured against the lower historic figure.
96. The Council's latest five-year housing land supply position statement indicates a supply position marginally above five years. That position relies in material part on windfall delivery assumptions and other components which, while capable in principle of contributing to supply, introduce sensitivity to the assumptions applied and to delivery performance. In plan-making terms, the implication is not that the Council should abandon windfall assumptions, but that the allocations portfolio should be sufficiently resilient such that any slippage in windfalls, strategic components or lead-in times does not result in under-delivery against the Plan's higher requirement.
97. The Preferred Options Plan also includes reliance on strategic components, including the Tendring Colchester Borders Garden Community, with an assumed contribution within the plan period. As set out earlier, strategic new settlement delivery can be subject to programme risk and infrastructure dependencies. The Plan should therefore avoid over-reliance on any single strategic component and should include a realistic contingency margin in the overall supply, supported by a balanced portfolio of sites with varied lead-in profiles and delivery characteristics.

98. In that context, the Council should ensure that the Proposed Allocations list includes sufficient deliverable and developable opportunities beyond existing commitments, so that the Plan can achieve the requirement in practice over the plan period. This includes identifying strategic allocations that can contribute materially to supply and also deliver wider plan objectives, including economic growth, rural vitality and environmental enhancement through masterplanning.
99. Land at Wormingford Airfield should be assessed and progressed through this allocation lens. The Site is already within the Council's assessed site pool through the SLAA process (recorded as "Fairfields Farm Wormingford Airfield", Site ID 10638). It is promoted as a strategic mixed-use opportunity which can, in principle, provide a meaningful additional source of housing delivery within the plan period, while also supporting the rural economy through the retention and planned expansion of established employment activity.
100. The Site is not promoted on the basis that it is unconstrained or that delivery would be automatic. It is in the countryside and would need to be shaped through landscape-led masterplanning, sustainable movement measures and proportionate environmental mitigation in line with the Plan's policy framework. The point for allocations is that the Site has the characteristics of a strategic, comprehensively planned opportunity where those matters can be addressed through allocation criteria and masterplanning, rather than being left to piecemeal and reactive decision-making.
101. Allocating the Site would also support the Plan's economic strategy. The Council's Employment Study identifies a quantitative shortfall in employment land supply relative to forecast demand and highlights the importance of supporting investment and flexibility in the local economy. The Site's mixed-use proposition, including the retention and expansion of existing employment activity, aligns with that direction and provides an opportunity to integrate homes and jobs, which in turn can assist in reducing out commuting pressures in principle and improving the overall sustainability balance.
102. From a plan effectiveness perspective, the Council should recognise the value of strategic mixed-use allocations in strengthening deliverability. Strategic sites can internalise and fund infrastructure and mitigation, provide flexibility in layout and phasing, and deliver green and blue infrastructure as an organising framework. This aligns with national policy which recognises that the supply of large numbers of new homes can often be best achieved through larger scale development, provided such schemes are well located and supported by infrastructure and deliver at a realistic rate.

103. We therefore request that, as the Preferred Options Plan progresses, the Council takes the following steps in relation to Growth and Opportunity Areas and Proposed Allocations. Those steps are intended to ensure the Plan is deliverable, resilient and capable of meeting the housing requirement in practice, while enabling strategic mixed use opportunities to be assessed fairly and transparently:
The Council should ensure that Wormingford Airfield is transparently tested as a reasonable alternative through the Sustainability Appraisal and site selection process, with clear reporting of the reasons for selection or rejection against the spatial strategy, housing delivery requirements and environmental policy framework.
The Council should ensure that the allocations portfolio is calibrated to the higher local housing need-led requirement and includes a realistic contingency margin, rather than relying on narrow headroom, sensitive windfall assumptions or optimistic build-out trajectories.
Subject to that testing, the Council should progress Land at Wormingford Airfield as a proposed allocation in the next iteration of the Plan, framed as a strategic mixed-use site with criteria-led requirements for masterplanning, access and sustainable movement measures, landscape-led design and environmental mitigation, and the retention and support of established employment activity.
104. In summary, the effectiveness of the Preferred Options Plan will depend on whether the Growth and Opportunity Areas and Proposed Allocations deliver a portfolio that is genuinely capable of meeting the Plan's housing requirement over the plan period, with sufficient flexibility and contingency to manage delivery risk. Land at Wormingford Airfield is a credible strategic option within the assessed site pool which can assist in strengthening that portfolio through a mixed-use allocation proposition aligned with both housing delivery and economic objectives.


Summary and Requested Modifications

105. For the reasons set out in these representations, we support the Council's intention to plan positively for housing delivery through the Preferred Options Local Plan, including the approach in Draft Policy ST5 of aligning the housing requirement with the local housing need position. However, the soundness of the Preferred Options Plan will ultimately depend on whether the spatial strategy and proposed allocations represent the most appropriate reasonable alternatives and whether they are capable of being

delivered in practice throughout the plan period, with realistic delivery assumptions and an adequate contingency margin.
106. The Plan's overall effectiveness is sensitive to delivery risk. This is particularly relevant where the housing strategy relies materially on strategic components and assumptions which may be subject to programme slippage over a long plan period. In that context, it is essential that the Plan maintains a balanced portfolio of sites and does not overly rely on narrow headroom in the supply position or on optimistic trajectories. A resilient strategy should provide choice and flexibility so that housing needs can still be met if some elements of supply deliver later than anticipated.
107. Land at Wormingford Airfield (Fairfields Farm, SLAA Site ID 10638) is a credible strategic site within the Council's assessed pool and should be tested and progressed as a proposed allocation in the next iteration of the Plan. The Site is promoted as a strategic mixed-use opportunity and is distinguished by the presence of established employment activity and the potential to align planned housing delivery with retention and expansion of the rural economy through a coordinated, masterplanned approach. The promotion is advanced on an "in principle" basis and is not intended to commit to a fixed quantum of housing or a fixed delivery programme at this consultation stage. Rather, it is intended to demonstrate that the Site is capable of contributing meaningfully to the Plan's objectives and to strengthening the robustness of the supply portfolio.
108. The policy framework within the Preferred Options Plan provides appropriate mechanisms to shape the Site, including through countryside and sustainability criteria, environmental and green network requirements, and the economy policies that support rural employment. Taken together, the Plan is capable of accommodating a strategic allocation here, subject to appropriate criteria and evidence at the relevant stages. The key plan-making issue is therefore whether the Council is willing to test and progress the Site transparently as a reasonable alternative, given the need for a deliverable and resilient allocations portfolio.
109. In order to ensure that the Plan is justified and effective, the Council should make the following modifications:
Progress Land at Wormingford Airfield (Fairfields Farm, SLAA Site ID 10638) as a proposed allocation in the next iteration of the Local Plan, framed as a strategic mixed-use site capable in principle of making a meaningful contribution to housing delivery over the plan period alongside the retention and support of established employment activity.

Ensure that the Site is transparently assessed and reported through the site selection and Sustainability Appraisal process as a reasonable alternative, including clear reasons for selection or rejection against the spatial strategy, housing delivery requirements, countryside policy framework, and environmental and economic objectives.
Calibrate the allocations portfolio and delivery trajectory to the higher local housing need-led requirement and ensure that the Plan's supply position includes a realistic contingency margin, rather than relying on narrow headroom or sensitive assumptions that could be vulnerable to slippage.
Where strategic components are relied upon for supply within the plan period, ensure that their assumed delivery profile is realistic and supported by clear evidence and infrastructure programming, and ensure that the wider allocations portfolio provides resilience in the event of delay.
110. If the Council is not minded to progress the Site as a proposed allocation at this stage, a clear alternative would be to identify it expressly as a contingency allocation to be released if monitoring indicates under-delivery. However, the preferred position remains that the Site should be progressed now, through the Preferred Options Plan process, so that it can be assessed properly through reasonable alternatives testing and, subject to that evidence, provide an additional strategic allocation that strengthens the Plan's deliverability and resilience over the plan period.

1 INTRODUCTION
Context
Gladman Developments Ltd. (Gladman) welcome the opportunity to comment on the
Colchester City Council Preferred Options as part of the Local Plan Full Update and
request to be updated on future consultations and the progress of the Local Plan.
Gladman specialise in the promotion of strategic land for residential development
and associated community infrastructure and have considerable experience in
contributing to the development plan preparation process having made
representations on numerous planning documents throughout the UK alongside
participating in many Examinations in Public.
This submission provides Gladman’s formal representations to the Regulation 18
consultation.
Gladman Developments have several land interests in Colchester City’s authoritative
area which are being promoted through the emerging Local Plan Update. The
following sites were submitted to the Call for Sites and are considered to be suitable
and sustainable locations for development:
• Land off Baker’s Lane, Braiswick (around 100 dwellings, policy reference PP7)
• North-East Colchester (west of Harwich Road, cumulating approximately 750
of the total 2,000 dwellings of the entire allocation PP9)
• Land off Colchester Road, West Mersea (up to 100 dwellings)
• Land off Rowhedge Road, Colchester (up to 75 dwellings)
The sites are available, suitable, and deliverable for housing as summarised in Section
6 of this representation, and two of these sites (at Baker’s Lane and at Harwich Road)
are draft allocations. Gladman looks forward to engaging further with the Council as
the plan progresses.
This submission also has been produced largely utilising the 2024 NPPF (National
Planning Policy Framework) regulations recognising that the Council are seeking to
submit their Local Plan before the December 2026 deadline. We note that a revised
NPPF consultation has very recently been announced (on 16th December 2025), and
therefore the council will need to carefully consider any potential implications for the
emerging Local Plan.
One minor house-keeping comment would be that draft local plans are often very
long documents, and so it is useful for the reader to have access to the whole
document as one, single, PDF file. Unfortunately, the draft plan is not available in this
format and we found it difficult to navigate the document via the website portal,
which requires scrolling through the web pages. A single file that can be downloaded
is therefore requested for future consultations.
2 LEGAL COMPLIANCE
Duty to Cooperate
The Duty to Co-operate, as a legal test, has now been rescinded by the Levelling Up
and Regeneration Act, which received Royal Assent on 26 October 2023. However,
engaging with prescribed bodies on relevant strategic and cross boundary matters
remains an important part of the plan making process.
The revised Framework introduced a number of significant changes to how local
planning authorities are expected to cooperate including the preparation of
Statement(s) of Common Ground (SoCG) which are required to demonstrate that a
plan is based on effective cooperation and has been based on agreements made by
neighbouring authorities where cross boundary strategic issues are likely to exist.
Planning guidance sets out that local planning authorities should produce, maintain,
and update one or more Statement(s) of Common Ground (SoCG), throughout the
plan making process.
. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for
strategic cross-boundary matters and will need to demonstrate the measures local
authorities have taken to ensure cross boundary matters have been considered and
what actions are required to ensure issues are proactively dealt with e.g. unmet
housing needs.
Sustainability Appraisal
In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act,
policies set out in Local Plans must be subject to Sustainability Appraisal (SA).
Incorporating the requirements of the Environmental Assessment of Plans and
Programmes Regulations 2004, SA is a systematic process that should be undertaken
at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s
proposals on sustainable development when judged against reasonable alternatives.
The Council should ensure that the results of the SA process conducted through the
preparation of the Local Plan clearly justify the policy choice made, including
proposed site allocations (or decisions not to allocate sites) when considered against
reasonable alternatives. In meeting the development needs of the area, it should be
clear from the results of the assessment why some policy options have been
progressed and others have been rejected.
The SA must demonstrate that a comprehensive testing of options has been
undertaken and that it provides evidence and reasoning as to why any reasonable
alternatives have not been pursued. A failure to adequately give reasons in the SA
could lead to a challenge of the Council’s position through the examination process.
The SA should inform plan making. Whilst exercising planning judgement on the
results of the SA in the Local Plan is expected, the SA should still clearly assess any
reasonable alternatives and clearly articulate the results of any such assessment.

3 NATIONAL PLANNING GUIDANCE
National Planning Policy Framework
The National Planning Policy Framework (NPPF) sets out the Government’s planning
policies for England and how these should be applied within which plan-making and
decision-taking. The NPPF requires plans to set out a vision and a framework for
future development and seek to address the strategic priorities for the area. Local
Plans should be prepared in line with procedural and legal requirements and will be
assessed on whether they are considered ‘sound’.
The National Planning Policy Framework sets out four tests that must be met for Local
Plans to be considered sound. In this regard, we submit that in order to prepare a
sound plan it is fundamental that it is:
• Positively Prepared – The Plan should be prepared on a strategy which seeks
to meet objectively assessed development and infrastructure requirements
including unmet requirements from neighbouring authorities where it is
reasonable to do so and consistent with achieving sustainable development.
• Justified – the plan should be an appropriate strategy, when considered
against the reasonable alternatives, based on a proportionate evidence base.
• Effective – the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy – the plan should enable the delivery of
sustainable development in accordance with the policies in the Framework.
The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are
in place which provide a positive vision for the areas which they are responsible for,
to address housing, economic, social and environmental priorities and to help shape
the development of local communities for future generations.
To support the Government’s continued objective of significantly boosting the supply
of homes, it is important that the Colchester City Council Local Plan provides a sufficient amount and variety of land that can be brought forward, without delay, to
meet housing needs.
In determining the minimum number of homes needed, strategic plans should be
based upon a local housing needs assessment defined using the standard method,
unless there are exceptional circumstances to justify an alternative approach.
Once the minimum number of homes that are required is identified, the strategic
planning authority should have a clear understanding of the land available in their
area through the preparation of a strategic housing land availability assessment. In
this regard, paragraph 67 sets out specific guidance that local planning authorities
should take into account when identifying and meeting their housing needs. Annex
2 of the Framework (2024) defines the terms “deliverable” and “developable”.
Once a local planning authority has identified its housing needs, these needs should
be met as a minimum, unless any adverse impacts would significantly and
demonstrably outweigh the benefits of doing so. This includes considering the
application of policies such as those relating to Green Belt and giving consideration
as to whether or not these provide a strong reason for restricting the overall scale,
type and distribution of development (paragraph 11b)i.). Where it is found that full
delivery of housing needs cannot be achieved (owing to conflict with specific policies
of the NPPF), Local Authorities are required to engage with their neighbours to ensure
that identified housing needs can be met in full.
As outlined in our Introduction section, a revised NPPF was announced on 16th
December 2025. In light of this, the council will need to ensure that any future
consultations for this draft Local Plan are compliant with this revised version. In the
interim, this rep has been submitted largely in conjunction with the 2024 version of
the NPPF.
Planning Practice Guidance
The need to plan for the sufficient delivery of homes is affirmed in the Written
Ministerial Statement (WMS) given by the then Deputy Prime Minister, and Secretary of State for Housing, Communities and Local Government, Angela Rayner on 30 July
2024, in addition to the on-going consultation on proposed revisions to the
Framework and other changes to the planning system.
The WMS reaffirms that the country is in “the most acute housing crisis in living
memory” and is clear in its conclusion that “there is no time to waste. It is time to get
on with building 1.5 million homes”. These are now material considerations for plan
making and decision making and clearly set the tone and direction of the newly
elected Government.
4 REGULATION 18 CONSULTATION
Introduction
The sections that follow below include comments from Gladman on the overall
strategic approach taken by the council, as well as reviewing some of the proposed
policies and site allocations.
The minimum end date of the plan should be 15 years from adoption, as per
paragraph 22 of the Framework. At present, it is difficult to follow which year is the
starting point for the plan period – in the draft plan under para 2.14 it confirms the
plan period is 2025-2041, however in Section 14, Appendix A, Table 14.1 (when
confirming the new policies over the previous draft policies) it is stated that the plan
period is 2026-2041. The plan seemingly seeks to cover the period 2025 or 2026 to
2041, resulting in either 15 or 16 years being planned for. Clarity is sought on this
regarding the start date.
The most appropriate starting date of the two is 2026. The standard method is a
forward-looking assessment of need taking into account both under and oversupply
in its methodology and uses a base period that is required to start in from the year
that the housing need is calculated. In order to be consistent with national policy,
Gladman would recommend that the plan period to start in the most recent year in
which the housing need is calculated.

Additionally, our experience of Local Plan examinations suggests that delays to the
local plan-making process are inevitable, and so the plan period only going to 2041,
i.e. 15 or 16 years from the Regulation-18 consultation, is too short. It is advisable,
therefore, to look beyond 2041 to ensure that the required period is covered
regardless of any likely delays. It is suggested that the plan period be amended to at
least 2026-2043.
A Settlement Hierarchy for Colchester
Settlement Hierarchy
The settlement hierarchy is presented under draft policy ST3: Spatial Strategy, giving
5 separate tiers, as well as open countryside.
Gladman consider that the draft settlement hierarchy is appropriate for the growth
of the authoritative area for the plan period. The proportionate distribution of growth
is important to ensure that settlements – both large and small – remain sustainable
and that growth takes place in locations which can support it.
Gladman are promoting sites across the settlement hierarchy in Colchester (three
sites) as well as one in West Mersea, which has Large Settlement status in the draft
plan. These site promotions are suitable and sustainable locations due to the range
of services and facilities they provide, the sustainable public transport choices
available and quality of life they offer residents. New development in these locations
can contribute to the vitality and viability of local services, stimulate the local
economy through increased resident expenditure and support local education and
healthcare facilities through S106 and/or CIL contributions.
Housing Figures and Requirement and Growth Strategy
Draft policy ST5: Colchester’s Housing Need provides details of the housing numbers
required over the plan period, with the plan period here stated as being 2025-2041
(16 years). It confirms that at least 20,800 new homes are needed to meet the future
housing need, equating to 1,300 dwellings per year.

In determining the minimum number of homes needed, strategic plans should be
based upon a local housing needs assessment defined using the standard method,
unless there are exceptional circumstances to justify an alternative approach.
We note in draft policy ST5 that provision will be made for at least 20,800 new homes
across a range of tenures. These are broken down by: existing commitments, Tendring
Colchester Borders Garden Community, windfall and the local plan allocations. These
four give a combined estimated total of 21,106 dwellings.
These figures allow for a 308-dwelling buffer from the housing need, equating to a
1.48% buffer on what is needed over the 16-year period. This figure is far too low to
be sustainable and relies too heavily on all of the allocations coming forward with the
estimated dwellings numbers, as well as appropriate windfall levels being available. It
is advisable that this buffer is increased to provide more confidence that the housing
need is met.
In light of this, it is suggested that more sites should be identified in order to ensure
that the need of 20,800 is not met. The most appropriate way to approach this would
be to include a greater number of short-medium sized sites, as these not only assist
with the overall housing need but also greatly assist with delivery in the first few years
of a local plan.
Gladman is promoting such sites in West Mersea, which can accommodate around
100 dwellings, and off Rowhedge Road, Colchester, which can accommodate around
75 dwellings. Further detail on this can be found in Section 6: Site Submissions below.
Further, the need for affordable homes is a pressing issue, and the Council may wish
to pursue a higher housing requirement to maximise the delivery of affordable
homes. This approach has been progressed by East Riding of Yorkshire.
Draft Policy ST3 sets out the strategy for growth across the authority area. The
planned growth within the draft plan is concentrated in existing settlements in a
proportional manner to ensure that there are sustainable levels of growth in
appropriate locations (i.e. utilising the settlement hierarchy).
In principle, Gladman consider such an approach to be suitable, however, there are
elements of this which require review.
Whilst we agree with this proportionate approach, the numbers which add up to meet
the housing need across the plan period are so fine that it would appear that there
are several sites that the plan is lacking to ensure that the housing need is met. To
continue with the proportionate approach using the settlement hierarchy, we would
recommend that more small-medium sized sites are allocated across the settlements.
As advised, such sites assist with both the overall housing need and also greatly assist
with delivery in the first few years of a local plan. Having more planned development
will also take the pressure off the dependence for windfall development to come
forward. The windfall reliance accounts for around 10% of the housing need, which
in our experience in Examinations is not wholly supported by the Planning
Inspectorate. It is therefore advisable to allocate more sites to reduce the windfall
dependency.
In the first instance, we submit that such sites should come forward in the larger
settlements, such as Colchester and the Large Settlements, and that Gladman’s land
interests at Baker’s Lane, West Mersea and off Rowhedge Road, Colchester would be
ideally positioned to fulfil this role.
The Rowhedge Road site lies adjacent to the Colchester Urban Area, is sustainably
located in relation to the city’s services and amenities and further development in the
location can be successfully assimilated into the existing settlement and its
surroundings. In addition to its status as a Large Settlement, West Mersea is the only
designated Large Settlement in the hierarchy for some distance geographically, such
that growth here will help support the wider area as a growth hub, which helps
support the Small Settlements of East Mersea, Peldon, Great Wigborough and Salcott.
Further information on our sites in West Mersea and land off Rowhedge Road can be
found in Section 6 below.
Finally, whilst not strictly concerned with housing numbers and growth, Policy ST2:
Environment and Green Network Sites sits alongside the Local Plan’s other suite of proposed Strategic Policies, and seeks to identify “Strategic Areas that present the best
opportunities for habitat creation and enhancement aimed at improving biodiversity”,
which it states are shown on the policies maps as ‘strategic biodiversity areas’. The
policy goes on describe how these areas will be protected, with support given to
strengthening and enhancing connections between habitats to improve the
contribution to the biodiversity network.
As outlined above, Gladman submit that there may be a requirement to identify
additional sites to ensure Colchester’s housing needs are met. At this stage, we
therefore suggest that there may be a corresponding need to review any policies that
may be relevant to achieving this objective, which could include Policy ST2.
In this regard, we question whether the ‘protection’ of ‘strategic biodiversity areas’ is
appropriate (if this is what the policy is proposing), and query whether the Local Plan
should be taking a more balanced approach, which could recognise that development
proposals can often provide the opportunity to secure the long-term management
of green infrastructure. Gladman reserve the right to comment on this policy and any
supporting evidence base documents in response to future consultations.
Development Management Policies
Draft Policy GN5 – Suitable Alternative Natural Greenspace
We generally agree with the principle of this policy, however Blackwater Estuaries
Special Protection Area is the main reason for our site in West Mersea not being
allocated for residential development. Given that there are mitigation measures
available under draft policy GN5, it is unclear why the site has been ruled out so
hastily.
Draft Policy LC3 – Coastal Areas
Policy LC3 seeks to take forward Colchester’s Coastal Protection Belt designation, as
presently covered by adopted Section 2 Local Plan Policy EN2. The policy advises that
in such areas of the borough an integrated approach to coastal management will be
promoted and development will only be supported if it meets certain criteria.
As detailed in Section 6 of these submissions below, Gladman are currently promoting
Land off Rowhedge Road, Colchester, which is situated within the Coastal Protection
Belt as defined on the Council’s draft Policies Map. The supporting text to Policy LC3
advises that its purpose “is to protect Colchester’s rural and undeveloped coastline from
inappropriate development that would adversely affect its rural, undeveloped and open
character…“. However, we question whether circumstances of the Rowhedge Road
site are consistent with these characteristics.
The Rowhedge Road site lies adjacent to the existing Colchester urban area, with
existing areas of development adjoining the site the south east and west, and existing
areas of woodland planting bordering the site to the north and east. Any
development in this location would be experienced as part of the existing built-up
area, would be well contained from its wider context, including the Colne Estuary, and
would be accompanied by a comprehensive framework of green infrastructure and
landscaping.
We therefore query how development in this location could adversely affect the rural,
undeveloped and open character of Colchester’s coastline, and how including the
Rowhedge Road site within the Coastal Protection Belt designation is consistent with
these aims. We would request that the inclusion of the Rowhedge Road site within
the Coastal Protection Belt designation is reviewed.
As detailed in Section 6 of these submissions, we submit that Land off Rowhedge
Road is well positioned to accommodate further residential development to meet
Colchester’s needs, and that it could do so successfully without adversely affecting to
the site’s setting and surroundings.
Draft Policy NZ1 – Net Zero Carbon Development (in operation)
We disagree with the need for this policy. Whilst we acknowledge the importance of
new dwellings being environmentally sustainable for future generations, such
requirements will be made under national policy, thus making a development
management policy on this aspect unnecessary. We would therefore request that this
policy be removed and left for the national building regulations to accommodate.

However, should this policy remain, we would request that instead of all dwellings,
that a percentage of dwellings per site be built out to the standards requested. This
would result in net-zero carbon dwellings still being built out, but without the
detriment of unaffordability for those seeking to buy, as ultimately the additional
costs incurred in making dwellings net-zero will be reflected in the house prices and
therefore the fall upon purchaser.
Draft Policy H6 – Self and Custom Build
We support this policy. Requesting 2% of large developments to be self/custom build
plots is appropriate, as this is a reasonable number and does not negatively impact
smaller schemes with mandatory self/custom build requirements, as the requirement
is only for schemes of 150+ dwellings. This is provided that the evidence supports
these figures.
We also agree with the 12-month turnaround time on the Self-Build Register, with
sales on the open market taking place after this period should the plot(s) not be
purchased.
5 SITE ALLOCATIONS
General Approach and Housing Trajectory
As above, the 20,800 dwellings required over the plan period are expected to come
forward in four possible ways: existing commitments, Tendring Colchester Borders
Garden Community, windfall and the local plan allocations.
Gladman agrees with the proportionate approach and agrees with the residential
allocations that have been included.
However, as outlined above, there is very little room for error in terms of housing
numbers (308 across the entire plan period). Given this tight margin, it would be
appropriate to seek further small to medium sized sites for allocation to assist with
these margins, as well as assure a 5-year housing land supply (as such sites tend to
come through in the early years of a local plan).

As advised, Gladman are promoting sites in West Mersea and Rowhedge Road which
are wholly appropriate to assist in this regard. Further details are in Section 6: Site
Submissions below.
6 SITE SUBMISSIONS
Land off Baker’s Lane, Braiswick
Land off Baker’s Lane is a highly sustainable location for growth in the draft local plan
and lies within the proposed settlement boundary for Colchester. This allocation
(reference PP7) is around 18.5 acres and can provide around 100 dwellings. Gladman
strongly support the inclusion of this site in the plan, and it is available, deliverable
and achievable to bring a positive level of residential development to the settlement.
The site lies in a natural direction of growth to the west of the settlement, with recent
development taking place to the east of the site. The site also lies within reasonable
walking distance of Colchester Train Station, as well as the nearby primary school and
nursey. Additionally, there are two public rights of way (PROWs) joining the site on
its western boundary, again emphasising the site’s strong pedestrian linkages to its
surrounding areas.
Gladman are seeking expert advice for pedestrian connections to the existing footway
on Baker’s Lane. We are also open to the possibility of a safe and appropriate
pedestrian crossing if required.
An appropriate buffer will be provided on any application for the Moat Farm Dyke
scheduled monument to the east of the site. We are currently liaising with experts on
this matter to ensure the best possible outcome for this aspect.
Highways access can easily be obtained along the western boundary of the site, with,
given the limited space along Baker’s Lane, pedestrian footpaths being available
within the site’s boundary as part of a future scheme.

A policy-compliant level of affordable housing will be provided, in a range of sizes
and tenures. The site will accommodate a range of house types and sizes informed
by local need.
The site acts as a crucial gatekeeper for future growth of Colchester in a westerly
direction, with possibilities to the south and west of this site becoming available after
development here at Baker’s Lane. Development of this site is therefore crucial for
any future growth of the settlement in a westerly direction.
North-East Colchester
As aforementioned, Gladman are promoting a 97-hectare site at North East
Colchester (west of Harwich Road) for a residential led development comprising
approximately 750 homes, a local centre, a two form entry primary school and
strategic green space. This site forms part of a larger site allocated for around 2,000
homes under draft Policy PP9. In accordance with the requirements of draft Policy
PP9, Gladman have worked alongside other land promoters and developers who own
or control land within the remit of Policy PP9 and have prepared a Masterplan
Framework jointly with Gleeson, but with input from other parties with smaller land
holdings, including Taylor Wimpey and Mrs Julie Clinch. The Draft Masterplan
Framework (‘the Framework’) can be found at Appendix 1, appended to this
submission’s email.
The purpose of the Framework is to articulate a vision for the future development of
North East Colchester. It seeks to set out shared objectives, spatial principles and
development aspirations that could guide the successful delivery of the site, aligning
with the requirements of national and local planning policy, including the
expectations of emerging Policy PP9. Following this Regulation 18 consultation,
further engagement with Colchester City Council and other key stakeholders will be
undertaken with regards to the content of the Framework.
The Framework is underpinned by a series of technical studies undertaken on
Gladman and Gleeson’s sites, forming a clear and strong evidence base to the proposals. Together these assessments have informed a constraints and
opportunities mapping exercise, which has assisted with preparing a deliverable
Masterplan that could accommodate the requirements and expectations of the draft
Policy PP9. This includes the expectation that the allocation would provide land for a
new primary school and a local centre. As discussed below, it is considered that the
Harwich Road site would be the optimum location to accommodate these facilities.
Gladman is supportive of the allocation of land west of Harwich Road as part of the
North East Colchester allocation. The Framework has been prepared jointly with
Gleeson to demonstrate that the site can viably deliver all of the requirements set out
by the policy. Each of these requirements in so far as that they relate to the Gladman
site are discussed in further detail below.
Land Uses and Infrastructure Provision
Draft Policy PP9 anticipates the delivery of approximately 2,000 new dwellings of a
mix and type of housing to meet evidenced needs which is compatible with
surrounding development. Applying a range of locally appropriate densities across
the Gladman site, around 750 dwellings could be delivered which would include 1-5
bedroomed homes in a range of house types.
As demonstrated by the Framework, the Gladman site will deliver a number of
additional services and facilities that will be available for new and existing residents.
A 1-hectare Local Centre will be delivered on-site, providing small scale retail and
community uses and offering economic and social benefits. A 2.1-hectare site for a
new two form entry primary school is also proposed by the Framework on the site,
increasing the offer of education facilities within the locality in accordance with the
emerging policy and the proposed requirements of the Local Education Authority.
The decision has been made to accommodate all community uses (local centre,
school and strategic open space) required by draft Policy PP9 on the Gladman
controlled site to the west of Harwich Road, as the physical attributes of the site, as
well as opportunities for safe and suitable access are most favourable compared with
other land parcels within the allocation. The proposed location within the centre of the Gladman site will ensure that the community uses and the proposed school can
benefit from strong frontage and visibility along the primary route from Harwich
Road. Gladman are therefore able to provide certainty around the delivery of this
necessary public infrastructure, as these uses will be proposed as part of a future
outline application submitted by Gladman, should the site be allocated within the
Local Plan.
Highways and Access
The Site is sustainably located in respect of access to facilities and services, including
public transport, with methods of travelling other than private car a viable option for
future occupiers. Furthermore, public transport connections could also be available
from within the site with the primary access route running through the development,
which will be of the necessary standard to accommodate a bus route connecting St
John’s Road to Harwich Road.
Draft Policy PP9 notes a requirement for safe and suitable site access to required
highway design standards. With regards to the Gladman site, the Framework propose
two primary access points off Harwich Road and one primary access point off St Johns
Road. Initial feasibility studies confirm that safe and suitable access can be provided
in these locations, supported by the introduction of traffic-calming measures to
Harwich Road to improve walkability and a creation of a new safe crossing at the
intersection with the active travel corridor.
In response to the requirement for the provision of active and sustainable travel and
ensuring connectivity with existing Public Rights of Way the Framework will deliver
an enhanced pedestrian and cycle network. As well as a primary active travel corridor
linking the Gladman site to the wider PP9 allocation. the Framework also illustrates
the provision of a secondary active‑travel route within the Gladman site, connecting
Bullace Close, Dunthorne Road and Harwich Road. These key networks will be
supported by a wider network of formal and informal footpaths that link the local
centre with dwellings within the site and surrounding communities.

Account has also been taken of land within the allocation to the north of the Gladman
site, which would require access to be taken through the Gladman site. The
Framework allows for vehicular and pedestrian access into this parcel to ensure
comprehensive development across the two sites.
Green and Blue Infrastructure Provision
Enhanced open space in excess of 10% of the total allocation area is required by draft
Policy PP9, including one area of ‘strategic’ open space, and multiple areas of
incidental open space. It is proposed that approximately 40% (38.12 hectares) of the
total PP9 allocation will be retained as green space, supplemented by additional POS
within development parcels.
The green and blue infrastructure strategy set out by the Framework brings together
existing woodland, hedgerows, trees, with new play spaces, amenity areas,
community growing spaces, SuDS features, natural and semi‑natural habitats, and a
connected path network. Their design and placement have been informed by
technical inputs and the ambition to create an integrated network that supports both
residents and biodiversity.
As demonstrated by the Framework, the Gladman site will accommodate an area of
strategic open space in the form of a new local park centred around an existing
mature oak tree which will act as a focal point for the new and existing residents. It
was agreed with all participating parties of the framework that the Gladman site was
the most appropriate location within the allocation for this community space due to
its flat topography, accessibility from existing surrounding communities (which will
be further enhanced) and the opportunity to create a community hub combined with
the local centre and school sites.
In response to the requirements of draft Policy PP9, an appropriate surface water
management strategy can be delivered. The Framework Plan identifies the indicative
location of Sustainable Drainage Systems (SuDS) to attenuate surface water, which in
relation to the Gladman site are indicatively located along the northern site boundary
following the advice of Gladman’s flood risk and drainage consultant. To support this, an initial Flood Risk Assessment (FRA) has been undertaken to evaluate potential
flood risks associated with the proposed development and to recommend suitable
mitigation measures, where necessary, to reduce flood risk to an acceptable level.
Protecting and enhancing Landscape Features
Draft Policy PP9 refers to a number of site-specific features which should be protected
and enhanced as part of future development proposals. Of particular relevance to the
Gladman site is the Bullock Wood SSI, is a designated ancient woodland which should
be appropriately buffered from development. The Framework demonstrates that
development will offset from Bullock Wood, allowing for a 15m wide corridor with
walking routes and incidental play, and a soft, informal green residential edge to the
ancient woodland. At the outline application stage, Gladman will seek to secure the
protection of the Ancient Woodland and retention of mature trees and hedgerows
within the site.
Summary
Gladman welcome the inclusion of the land at North East Colchester as a proposed
strategic allocation and hope the additional information provided within this
representation and enclosed Framework assists the Council in demonstrating that this
site is deliverable and suitable for an allocation in the Regulation 19 plan. The
Gladman site is wholly deliverable and can meet the site-specific requirements of
draft Policy PP9.
Land off Colchester Road, West Mersea
West Mersea is designated as a Large Settlement in the draft settlement hierarchy
(Policy ST3). With an estimated population of over 7,000, it is a highly sustainable
location for growth. Gladman are promoting land off Colchester Road for residential
development.
Land off Colchester Road (ref: 10748) is capable of delivering around 100 homes and
relevant community infrastructure. The entire site is approximately 12.5 acres, and it lies on the main access road into the settlement from the north. Colchester lies
around 5 miles from West Mersea, and given the site’s location the impact on the
roads in West Mersea will be minimal as most would head immediately north towards
the city.
The site comprises arable fields and 3 residential properties lying immediately to the
north-east of the site, with a fourth slightly further north, all on Paeony Chase. The
eastern and southern sides of the site run parallel with Colchester Road, with some
dwellings immediately to the site’s west and fields to the north-west. The site’s
location can be found in Figure 1 below. It is relatively flat in nature and has no flood
risk.
A policy-compliant level of affordable housing could be provided, in a range of sizes
and tenures. The site will accommodate a range of house types and sizes informed
by local need.
Suitable mitigation and precautionary measures will be implemented on site to
ensure that there are no significant adverse effects on ecology and 10% biodiversity
net gain can be achieved through new habitat creation and enhancement.
The negative impacts the site has been labelled with in the Sustainability Appraisal
are the impacts on Historic Environment and Landscape, with the latter presumably related to impacts on the estuary. However, whilst we acknowledge the importance
of such an environmental feature, this should not be a reason preventing this site for
allocation. In terms of proximity, the site lies several fields away from the estuary itself,
and there is already existing built form between the site and the estuary. The
aforementioned Paeony Chase consists of four dwellings, all of which lie closer to the
estuary than the site. There is therefore no additional encroachment to the estuary,
as the built form already exists – this site simply seeks to build up to the existing
dwellings.
Additionally, mitigations can easily be implemented on this site – its orthodox shape
allows for open space to be enjoyed to the north-west corner, thus maintaining a
buffer between any houses on this site to the estuary, whilst simultaneously allowing
for new and existing residents to enjoy the view of the estuary. Contrary to the site
assessments, residential development of this site can have a positive impact on the
estuary and given its location in the wider scheme of the settlement, its size and how
the settlement itself functions, makes it an ideal location for a sustainable residential
scheme.
There is one listed building near the site, which is the sole property on the northern
side of Paeony Chase. There is already built form between this building and the site,
meaning any visual impacts on the listed building from developing the site would be
minimal. Further, mitigation measures can be undertaken to minimise the any
potential impacts on the listed building.
Gladman have explored several assumptions concluded by the LPA pertaining to
residential land interests in the authoritative area. Fundamentally, Gladman do not
consider that the site at West Mersea should be discounted primarily due to potential
impacts made upon the estuary, and can provide the Council with information
regarding our design approaches to mitigate this harm. In the context of a significant
national housing crisis and a significant rise in market and affordable housing needs
in the District, Gladman do not consider it appropriate nor justified to discount the
site on the edge of a highly sustainable settlement without due consideration of how the site could be delivered through landscape-led design. We would welcome the
opportunity to discuss this site further, and the significant benefits it can deliver with
the Council.
Land off Rowhedge Road, Colchester
As discussed in our submissions above, Gladman are currently promoting Land off
Rowhedge Road, Colchester for residential development. The site extends to a total
area of 3.99ha, with the site’s location and the extent of the land under promotion by
Gladman shown in Figure 2 below.
Figure 2 Land off Rowhedge Road, Colchester - Location Plan
Located immediately adjacent to the Urban Area of Colchester, which forms the top
tier of the Council’s settlement hierarchy and the main focus for development within
the borough area, Gladman submit that Land off Rowhedge Road is ideally situated
to deliver residential growth to meet Colchester’s housing
Land off Rowhedge Road is not subject to any technical, landownership or viability
constraints that would preclude its development and delivery. This is further evidenced by the suite of technical assessments that have been prepared in support
of Gladman’s current planning application for the site (Colchester City Council ref:
251150) which is currently pending determination with the authority.
The remainder of this section describes the site’s suitability for development, taking
account of the technical studies that have been undertaken to inform its delivery to
date, and describes how it would represent a logical location for further sustainable
development.
New Homes
The site could accommodate up to 75 dwellings, delivering a range of market and
affordable homes to meet the borough’s housing needs. In accordance with the
Council’s emerging policy position, 30% of the homes would be delivered as
affordable housing. The proposals can be delivered at a density that makes efficient
use of the land whilst also being appropriate for the location and respecting its
character and surroundings.
Transport and Accessibility
Vehicular access to the site can be achieved from Rowhedge Road and will ensure
that both pedestrians and cyclists can access the site. Traffic surveys undertaken in
support of Gladman’s current application submission have shown that this access
could suitably accommodate the number of vehicle movements associated with the
proposals, whilst also demonstrating that the site’s development would not have an
unacceptable impact on the operation of the wider highway network or on highway
safety more broadly.
A good range of services and facilities can be accessed from the application site by
walking and cycling. The proposals lie in close proximity to the range of amenities
present within Old Heath, whilst also benefitting from access to the greater range of
facilities that are available in the wider Colchester urban area. The nearest bus stops
to the site are situated on Rowhedge Road with further bus stops located on
Fingringhoe Road. These stops are served by a regular service to Colchester city centre and also provide access to the wider bus network, as well as Colchester railway
station.
Ecology
The development of the Rowhedge Road site would not cause harm to any ecological
designations or protected species that cannot be addressed through appropriate
mitigation and enhancement measures. A comprehensive suite of ecology surveys
have the assessed the site’s potential to provide habitat for bats, badgers, dormice,
reptiles, riparian mammals and great crested newts; through the implementation of
precautionary working measures, habitat enhancement and accepted mitigation
methods, it has been concluded that no unacceptable impacts will arise in this
respect.
The proposed landscaping scheme for the proposals will help to improve the site’s
habitat structure and diversity. This could include new scrub planting, the retention
and enhancement of existing on-site hedgerows and woodland planting, and the
sowing of an appropriate grassland mix. Enhanced and created habitats will be
positively and appropriately managed to maximise their biodiversity value and the
contribution they can make to ecological networks. Biodiversity net gains would be
secured in accordance with national policy requirements.
Landscape
Gladman’s current application submission has been supported by the preparation of
a Landscape and Visual Impact Assessment (LVIA). This describes how the site could
accommodate residential development without giving rise to any unacceptable
landscape and visual effects, whilst also concluded that it does not constitute or form
part of a ‘valued landscape’.
Submissions on the Rowhedge Road site’s identification as part of the Coastal
Protection Belt are provided in response to Policy LC3 in Section 4 of these
representations above. In this regard, it is questioned whether the inclusion whether
the coverage of the Rowhedge Road site by this designation is appropriately justified.
It is understood that the purpose of the Coastal Protection Belt is protect the
borough’s coastline from development that would adversely affect its rural,
undeveloped and open character. However, it is questioned whether the Rowhedge
Road site exhibits these characteristics. Development on the site would be
experienced as part of an existing, built-up developed area, would be accompanied
by a comprehensive framework of green infrastructure and landscaping, and would
be well contained from its wider context, including the Colne Estuary.
Historic Environment
Gladman’s current application submission has been supported by a Heritage Desk
Based Assessment (HDBA), describing how the development of the Rowhedge Road
site would not affect the setting or significance of any listed buildings or locally listed
buildings due to the absence of any historical functional associations and invisibility.
The HDBA also concludes that any archaeological interest in the site could be
addressed via archaeological recording, if this is deemed necessary.
Flooding and Drainage
A comprehensive Flood Risk Assessment (FRA) has also been prepared in support of
Gladman’s current planning application. This identifies how the site could be safely
developed in relation to the risk of flooding. Any development would be situated
within Flood Zone 1, with no built development or other vulnerable uses at risk of
flooding from any other source.
A suitable drainage strategy delivered in accordance with Sustainable Urban Drainage
System (SuDS) principles would be provided, and would ensure the development of
the site would not give rise to an increased risk of flooding on-site or elsewhere. This
drainage strategy would also include a three-stage treatment train to ensure there
are no impacts on the receiving watercourse in relation to pollutants.
Infrastructure Provision
It is not anticipated that the proposals will give rise to any infrastructure deficiencies
that cannot be appropriately and adequately addressed. In this context. Gladman would be willing to enter into a Section 106 agreement with Colchester City and Essex
County Council to secure proportionate upgrades to infrastructure where these are
shown to be necessary to accommodate any development proposals.
Summary
As can be seen from the above summary, it can be satisfactorily demonstrated that
there are no infrastructure or technical constraints that would prevent the delivery of
a sustainable and acceptable residential development at Land off Rowhedge Road,
Colchester.
Gladman and the site’s owners would welcome the opportunity to work with the
authority’s officers to bring a suitable proposal for the site forward, and submit that
it would represent a suitable and sustainable location for further resident
development as part of the Council’s emerging Local Plan proposals.
7 CONCLUSIONS
Summary
Gladman have provided comments on a number of the issues that have been
identified in the Council’s consultation material and recommend that the matters
raised are carefully explored during the process of undertaking the new Local Plan.
Gladman are generally in support of the plan as drafted, with some key caveats
highlighted above in both the Development Management Policies section, as well as
sites not included for allocation.
The sites that have been selected as draft allocations are good options. Those which
Gladman are involved in at Baker’s Lane and North East Colchester are sustainable
sites that will strongly assist in meeting Colchester’s housing need. However, there is
a need to extend the plan period further to reduce the risk of it being too short (i.e.
under 15 years) and no longer being legally compliant.
Further, to extend by a few years requires more sites to be allocated to support the
extra years, which would help to increase the resilience of the Local Plan and the buffer between the planned supply of housing vs. identified needs. Gladman
proposes further small to medium sites to assist with this need, and these can be
captured in the first few years of the plan period, which can also assist greatly with
the 5-year housing land supply.
Gladman also request that a housing trajectory be published as soon as possible to
ensure appropriate levels of growth take place throughout the plan period.
We hope you have found these representations informative and useful towards the
preparation of the Colchester City Council Local Plan.
Gladman welcome any future engagement with the Council and if you would like to
discuss this representations or other matters, please contact us at
policy@gladman.co.uk.

see attached

see attached

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.