Richborough does not consider the Vision as drafted to be effective as it does not reference meeting housing needs, or housing in general.
Paragraph 11a of the NPPF is clear that plans should “promote a sustainable pattern of development that seeks to: meet the development needs of their area” and that “strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas”.
Paragraph 61 of the NPPF also states that “the overall aim should be to meet an area’s identified housing need, including with an appropriate mix of housing types for the local community”, and requires that “a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed”.
Richborough is therefore of the view that the ‘Vision’ should reflect the key challenge referenced above in respect of meeting housing needs throughout the plan period and acknowledge clearly within the Vision that development needs are to be met in full, including for market and affordable housing.

See attachment with detailed comments on numerous policies. Anglian Water welcomes the opportunity to contribute comments on the Draft
Local Plan for Colchester City Council. We consider that the Plan is well set out with in relation
to managing flood risk, surface water and wastewater, and enabling water efficiency. We
recognise the challenges for meeting the uplift in housing requirements and the
infrastructure required to help deliver future growth across the district, with the main
focus being Colchester and the larger towns.
We have raised some policy matters relating to consistency between policies addressing surface
water flood risk, water supply, and wastewater, and how these matters are attributed to site
allocation policies.
We look forward to continuing our positive and proactive discussions with the Council in
respect of our comments and the next iteration of the Local Plan, including supporting updates
to the evidence base if required

See attachment with detailed comments on numerous policies. Anglian Water welcomes the opportunity to contribute comments on the Draft
Local Plan for Colchester City Council. We consider that the Plan is well set out with in relation
to managing flood risk, surface water and wastewater, and enabling water efficiency. We
recognise the challenges for meeting the uplift in housing requirements and the
infrastructure required to help deliver future growth across the district, with the main
focus being Colchester and the larger towns.
We have raised some policy matters relating to consistency between policies addressing surface
water flood risk, water supply, and wastewater, and how these matters are attributed to site
allocation policies.
We look forward to continuing our positive and proactive discussions with the Council in
respect of our comments and the next iteration of the Local Plan, including supporting updates
to the evidence base if required

Spencer Planning Limited acts on behalf of Mr & Mrs Tim Knighton, the owners of 6.67 hectares (ha) of agricultural land to the northeast of Coach Road, Great Horkesley, as set out on the accompanying Site Location Plan (drawing no. X21482-01b). This land benefits from an existing access onto Coach Road.

Our clients support the Vision at paragraph 2.19 of the Local Plan Regulation 18 document, including its recognition that the local authority area will grow and change, and that this brings with it opportunity.

White Colne Parish Council welcomes the opportunity to comment on the Preferred Options Local Plan. Although White Colne lies within Braintree District, development proposed in the northwest of Colchester District will have a direct and significant effect on the village due to the shared A1124 transport corridor which links the Earls Colne / Wakes Colne area to Colchester.
In particular, White Colne Parish Council notes the following site allocations:
• PP28: Land West of Station Road, Wakes Colne – approx. 200 dwellings
• PP27: Swan Grove, Chappel – approx. 35 dwellings
• PP36: Great Tey – approx. 125 dwellings
• PP31 & PP32: Land North of Halstead Road, Eight Ash Green – approx. 300 dwellings combined
• PEP12: Wakes Hall Business Centre – employment expansion
Taken together, these allocations amount to well over 800 new homes in the immediate A1124 catchment between Great Tey / Wakes Colne and the western edge of Colchester. All vehicular movements from these sites will necessarily travel along the A1124 or its immediate feeder routes, and a significant proportion will pass through or impact White Colne, a rural village already experiencing high traffic volumes, issues with speeding vehicles, limited crossing points, no continuous footway on parts of the A1124, and bus service unreliability.
The draft plan requires individual developments to demonstrate that they will not be “detrimental to highway capacity or safety,” yet the cumulative impact of 800+ dwellings (plus new employment land) on the A1124 corridor has not been assessed.
White Colne Parish Council therefore requests:
1. A full cumulative highways impact assessment
This must consider all allocations that use the A1124 as their primary route into Colchester, including those in Wakes Colne, Chappel, Great Tey, and Eight Ash Green.
2. Identification of required mitigation measures
Including but not limited to:
• junction improvements,
• speed management,
• pedestrian safety enhancements,
• bus service improvements,
• measures to protect rural villages from increased through-traffic.
3. Cross-boundary engagement
Colchester City Council must work proactively with Braintree District Council, Essex County Highways, and White Colne Parish Council, as the impacts of proposed Policies will fall substantially outside Colchester’s own administrative boundary.
4. Recognition that infrastructure needs do not stop at district boundaries
The Local Plan should explicitly acknowledge the dependency of new development on the A1124 and commit to ensuring that rural communities such as White Colne are not disproportionately affected by growth elsewhere.

White Colne Parish Council supports sustainable, well-planned development. However, without a clear cumulative transport strategy, the draft plan risks delivering significant adverse impacts on road safety, noise, air quality, and the rural character of our village.

Please see comments in document submitted across a variety of policy areas.

See full text of the attachment for each policy which in some cases add extra information that couldn't be included fully in the rep summary.

see attached

Proposed Housing Allocations Affecting Copford with Easthorpe Parish
The Regulation 18 Draft Local Plan proposes two major housing allocations affecting Copford with Easthorpe Parish:
• Policy PP29 – Land east of School Road, Copford: approximately 300 homes
• Policy PP17 – Land behind shops off London Road, Marks Tey: approximately 1,500 homes, crossing the Marks Tey / Copford parish boundary, with an estimated 600 homes located within Copford with Easthorpe Parish
Together, these allocations represent an additional 900 homes within the Parish. Based on an average household size of three people, this equates to an increase of approximately 2,700 residents.
While I recognise the need to identify sites to meet the City-wide housing target of approximately 21,000 new homes, I have serious concerns about where and how these homes are proposed and whether the necessary infrastructure can realistically be delivered. The scale of development proposed for Copford with Easthorpe Parish is neither fair nor proportionate.
________________________________________
Conflict with the Vision and Objectives of the Local Plan
Section 2 (paragraph 2.19) of the Draft Local Plan sets out a vision of:
• “preserving Colchester’s identity” and
• “improving the quality of life of our residents”.
These are objectives I strongly support. However, the sheer scale of development proposed under PP17 and PP29 will have a significant and overall negative impact on this area. The scale, density and location of the proposed sites do not preserve local identity, rural character or biodiversity, and are therefore inconsistent with the stated vision of the Plan.
________________________________________
Policy PP29 – Impact on Rural Character and Heritage Assets
The proposed housing density under PP29 would result in a substantial erosion of the rural nature of the Parish.
While the seven Grade II listed buildings and the Copford Green Conservation Area may not be directly affected by the development boundary, they will be adversely impacted by the inevitable increase in traffic, noise and pollution generated by the proposal.
Although the Draft Local Plan refers to a City-wide Housing Needs Survey, it makes no reference to the Copford Local Housing Needs Survey, which should be a material consideration when assessing local housing requirements.
________________________________________
Policy PP17 – Cross-Boundary Development Concerns
With regard to Policy PP17, it is notable that Colchester City Council has recently refused an application for 175 homes in Tiptree, citing cross-boundary planning issues. Given this precedent, it logically follows that a proposal for 1,500 homes straddling the parishes of Marks Tey and Copford with Easthorpe should be subject to the same concern and scrutiny.
________________________________________
Infrastructure Constraints
In addition to the scale of development, I have serious concerns about whether essential infrastructure can support these allocations.
Wastewater Treatment and Water Supply
Copford Water Recycling Works has very limited remaining capacity, with only 33% permitted Dry Weather Flow (DWF) capacity remaining (Colchester Water Cycle Study – Interim Findings, February 2025). The study identifies a “high risk of water quality non-compliance”.
While the interim AECOM report suggests sufficient water supply for new development, it does not specify where this additional water will come from. There has been speculation that this will rely heavily on reducing domestic water consumption to below 100 litres per person per day, an assumption that is both uncertain and unrealistic. Furthermore, the report does not account for wastewater and water supply requirements arising from existing allocations, let alone new ones.
________________________________________
Road Network and Transport Impacts
There are already significant and well-documented problems on both the A12 and A120, with conditions on the A120 widely acknowledged as severe and unsustainable.
Additional housing will place further strain on these routes and will inevitably impact local roads, particularly:
• London Road (B1408), and
• School Road, the likely access route for PP29.
School Road is a major route to and from Copford Primary School, is already heavily congested at peak times, and is increasingly used as a rat run towards the A12 via Easthorpe Road and from Maldon Road via Fountain Lane and Aldercar. It is also used by HGVs.
Traffic generated by PP29 alone could result in up to 600 additional vehicle movements per day, significantly worsening congestion, pollution and road safety risks. This is of particular concern given the large number of children crossing School Road daily to attend the primary school. The proposal is therefore likely to result in an unacceptable impact on highway safety, and it is difficult to see how the policy objective of “safe pedestrian access” can realistically be achieved.
________________________________________
Active Travel and Public Transport
Policy ST1 – Health and Wellbeing promotes active travel, which is commendable in principle. However, it is difficult to see how increased walking and cycling can be realistically achieved in the context of:
• higher traffic volumes,
• increased congestion, and
• safety concerns along School Road, London Road (B1408) and the A120.
Rather than promoting healthier lifestyles, the development risks leading to:
• increased noise and air pollution,
• compromised air quality, and
• wider environmental harm.
The suggested mitigation of a modal shift towards public transport is also problematic. Public transport options are limited to bus services on London Road, which are infrequent outside peak hours and become increasingly poor the further one travels from the city centre. In these circumstances, private car use is likely to remain the dominant mode of transport.
________________________________________
Impact on the Local Environment and Biodiversity
Policy PP29 and Policy EN4 – Irreplaceable Habitats
The PP29 site lies adjacent to Pits Wood Local Wildlife Site. The proposed 15-metre buffer is inadequate given the sensitivity of the site and the presence of:
• large badger setts, and
• a population of nesting nightingales, a Red List endangered species.
The Woodland Trust recommends significantly larger buffer zones for development adjacent to ancient or sensitive woodland habitats. It is essential that full, seasonal ecological surveys are undertaken before any allocation is confirmed.
The potential enhancement of wildlife corridors linked to the Roman River corridor is welcomed, but this does not offset the likely harm arising from development at this location.
________________________________________
Health and Wellbeing – Healthcare Provision
The delivery of Policy ST1(f) relating to healthcare provision is questionable. Local GP surgeries are already operating at or beyond capacity and would be unable to accommodate the additional population generated by approximately 1,800 new homes, in addition to the 630 homes planned in Stanway. There are also ongoing concerns regarding hospital capacity.
Any new development must be accompanied by properly funded healthcare provision, including staffing, to meet the needs of a significantly increased population.
________________________________________
Community Facilities
Policies CS1 and CS2
Copford Village Hall is a well-used and financially viable community facility. While PP29 refers to its potential replacement, there are serious concerns:
• The Village Hall and associated land are registered with the Charity Commission, yet Draft Local Plan mapping suggests this land could be used for housing or access.
• Any transfer or redevelopment would require detailed negotiations between the developer, the Charity Commission and the current Trustees.
• An alternative approach could involve remodelling the existing hall and improving parking provision.
The local community must be fully involved in any decisions regarding the location and design of a new or improved Village Hall. The existing car park plays a vital role during the school run, helping to reduce on-street parking and congestion on School Road.
________________________________________
Education Provision
While the inclusion of a two-form entry primary school within PP17 is welcomed, this does not adequately address the combined impact of 300 homes from PP29 and 1,500 homes from PP17. Copford Primary School is already near capacity and would require significant investment to accommodate additional pupils.
There is also no clear information regarding provision for secondary or post-16 education. Local secondary schools are already close to capacity, and the projected increase in pupil numbers cannot be accommodated without substantial new provision.

see attached

see attached

are writing on behalf of our client, the Defence Infrastructure Organisation (DIO), which is part of the
Ministry of Defence and is responsible for managing the military estate, including the provision of homes
for service personnel across the UK.
We submit representations to the Colchester Regulation 18 Local Plan Consultation covering multiple
DIO-owned sites and strategic concerns regarding the emerging Local Plan. These representations
have been prepared to assist Colchester City Council in developing an effective and deliverable plan
that recognises both local priorities and national defence requirements.
In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and
development plans recognise that MOD Establishments are of strategic military importance to the UK.  It
is important that planning authorities consult with the MOD during the preparation of their plans and take
into account the need to safeguard operational sites.
To support the ongoing military training and operations within the City it is considered that the inclusion
of a specific policy in the Local Plan to recognise these requirements would be beneficial and accord
with national planning policy.
Paragraph 102 of the National Planning Policy Framework (December 2024) states that ‘planning
policies and decisions should promote public safety and take into account wider security and defence
requirements including by ‘b) recognising and supporting development required for operational defence
and security purposes, and ensuring that operational sites are not affected adversely by the impact of
other development proposed in the area.’
Summary of Other Representations
Land South of Birch Brook
Our client is concerned with the proposed designation of this defence land as a Strategic Biodiversity
Area under Policy ST2. We object to this blanket designation which could prevent continued
operational use and future land release requirements, thereby conflicting with national defence
objectives as recognised in NPPF Paragraph 102b.
We also raise significant concerns regarding the spatial strategy's over-reliance on large, complex
strategic allocations in village locations, which introduces substantial delivery risks. We estimate that
approximately 2,970-3,695 dwellings from major strategic allocations are at medium to very high risk
of non-delivery within the Local Plan period. The Plan requires greater flexibility, contingency planning,
and a more diverse range of site sizes and locations to maintain housing supply resilience as supported
by the NPPF.
Middlewick Ranges
Whilst we acknowledge the proposed de-allocation of this 120-hectare site as a housing allocation,
our client objects to the dual designation as both Local Green Space under Policy GN3 and Strategic
Biodiversity Area under Policy ST2. This approach creates unnecessary policy duplication and
potential conflicts that could harm proper ecological management and enhancement.
The Local Green Space designation is also inappropriate for extensive tracts of land where the primary
value lies in biodiversity function rather than recreational or community use, contrary to National
Planning Policy Framework (NPPF) Paragraphs 106-108. We request removal of the Local Green
Space designation to avoid policy confusion and constraints on effective habitat management as
required by the NPPF.
DIO Berechurch
This 3.6 hectare site is being considered for operational defence use, potentially including Service
Family Accommodation (SFA) development to address urgent identified needs. We object to its
proposed inclusion within a Strategic Biodiversity Area designation, which lacks robust evidential
justification and fails to recognise the site's operational importance in accordance with NPPF
Paragraph 102b.
We also highlight that there is an established operational requirement for the site for military purposes,
this includes the need deliver new Service Family Accommodation (SFA) to meet a significant shortfall
in provision in Colchester, yet the Local Plan provides no recognition or policy support for this
requirement contrary to national defence priorities set out in NPPF Paragraph 102b.
The site also contains existing electrical infrastructure and is surrounded by development on three
sides, questioning its suitability as a biodiversity area. We emphasise the need for operational flexibility
to adapt to changing defence requirements without undue policy constraints. We recommend inclusion
of a specific Military Establishments policy to support development that enhances operational
capability and recognise SFA provision as essential workers housing.
Open Space Designations Merville Barracks
Our client objects to the proposed designation of two parcels within our clients’ estates (at Drury
Meadows and Montgomery Estate) as Open Space under Policy GN6. These sites, totalling
approximately 2.17 hectares, are suitable for SFA infill development and do not provide demonstrable
public recreational or amenity value, nor is there funding identified within the Local Plan evidence base
for the long term management and maintenance of this land as open space. The designations lack
robust justification as the sites were not assessed within the Council's Open Space Report (2023),
rendering the approach unsound.
We highlight that there is an urgent need in Colchester to deliver new SFA, yet the Local Plan provides
no recognition or policy support for this requirement contrary to national defence priorities set out in
NPPF Paragraph 102b. We also recommend inclusion of a specific Military Establishments policy to
support development that enhances operational capability and recognise SFA provision as essential
workers housing.
Key Requested Revisions
We respectfully request the following amendments to strengthen the Plan's deliverability and
soundness:
1. Remove Strategic Biodiversity designations from operational defence land (Land South
of Birch Brook and DIO Berechurch).
2. Remove Local Green Space designation from Middlewick Ranges to avoid policy
duplication and given it is an extensive tract of land and therefore unsuitable.
3. Remove Open Space designations from SFA estate land or provide policy flexibility for
SFA development.
4. Include specific policy recognition and support for general defence requirements and
Service Family Accommodation provision.
5. Incorporate greater flexibility and contingency planning within the spatial strategy.
6. Diversify housing supply through a broader range of site sizes and locations.
7. Establish clear triggers for releasing reserve sites to maintain housing supply
resilience.
Conclusion
The DIO remains committed to working collaboratively with Colchester City Council to ensure the
emerging Local Plan provides an appropriate and flexible framework that recognises both local
housing needs and national defence priorities. Our representations seek to strengthen the Plan's
effectiveness, deliverability, and resilience whilst ensuring that essential defence operations can
continue without unnecessary policy constraints.
We believe that addressing these concerns will result in a more robust and sounder Local Plan that
better serves the needs of Colchester's communities whilst fulfilling the Council's obligations to support
national defence requirements.
We look forward to your consideration of these matters and to continued engagement throughout the
Local Plan process.

are writing on behalf of our client, the Defence Infrastructure Organisation (DIO), which is part of the
Ministry of Defence and is responsible for managing the military estate, including the provision of homes
for service personnel across the UK.
We submit representations to the Colchester Regulation 18 Local Plan Consultation covering multiple
DIO-owned sites and strategic concerns regarding the emerging Local Plan. These representations
have been prepared to assist Colchester City Council in developing an effective and deliverable plan
that recognises both local priorities and national defence requirements.
In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and
development plans recognise that MOD Establishments are of strategic military importance to the UK.  It
is important that planning authorities consult with the MOD during the preparation of their plans and take
into account the need to safeguard operational sites.
To support the ongoing military training and operations within the City it is considered that the inclusion
of a specific policy in the Local Plan to recognise these requirements would be beneficial and accord
with national planning policy.
Paragraph 102 of the National Planning Policy Framework (December 2024) states that ‘planning
policies and decisions should promote public safety and take into account wider security and defence
requirements including by ‘b) recognising and supporting development required for operational defence
and security purposes, and ensuring that operational sites are not affected adversely by the impact of
other development proposed in the area.’
Summary of Other Representations
Land South of Birch Brook
Our client is concerned with the proposed designation of this defence land as a Strategic Biodiversity
Area under Policy ST2. We object to this blanket designation which could prevent continued
operational use and future land release requirements, thereby conflicting with national defence
objectives as recognised in NPPF Paragraph 102b.
We also raise significant concerns regarding the spatial strategy's over-reliance on large, complex
strategic allocations in village locations, which introduces substantial delivery risks. We estimate that
approximately 2,970-3,695 dwellings from major strategic allocations are at medium to very high risk
of non-delivery within the Local Plan period. The Plan requires greater flexibility, contingency planning,
and a more diverse range of site sizes and locations to maintain housing supply resilience as supported
by the NPPF.
Middlewick Ranges
Whilst we acknowledge the proposed de-allocation of this 120-hectare site as a housing allocation,
our client objects to the dual designation as both Local Green Space under Policy GN3 and Strategic
Biodiversity Area under Policy ST2. This approach creates unnecessary policy duplication and
potential conflicts that could harm proper ecological management and enhancement.
The Local Green Space designation is also inappropriate for extensive tracts of land where the primary
value lies in biodiversity function rather than recreational or community use, contrary to National
Planning Policy Framework (NPPF) Paragraphs 106-108. We request removal of the Local Green
Space designation to avoid policy confusion and constraints on effective habitat management as
required by the NPPF.
DIO Berechurch
This 3.6 hectare site is being considered for operational defence use, potentially including Service
Family Accommodation (SFA) development to address urgent identified needs. We object to its
proposed inclusion within a Strategic Biodiversity Area designation, which lacks robust evidential
justification and fails to recognise the site's operational importance in accordance with NPPF
Paragraph 102b.
We also highlight that there is an established operational requirement for the site for military purposes,
this includes the need deliver new Service Family Accommodation (SFA) to meet a significant shortfall
in provision in Colchester, yet the Local Plan provides no recognition or policy support for this
requirement contrary to national defence priorities set out in NPPF Paragraph 102b.
The site also contains existing electrical infrastructure and is surrounded by development on three
sides, questioning its suitability as a biodiversity area. We emphasise the need for operational flexibility
to adapt to changing defence requirements without undue policy constraints. We recommend inclusion
of a specific Military Establishments policy to support development that enhances operational
capability and recognise SFA provision as essential workers housing.
Open Space Designations Merville Barracks
Our client objects to the proposed designation of two parcels within our clients’ estates (at Drury
Meadows and Montgomery Estate) as Open Space under Policy GN6. These sites, totalling
approximately 2.17 hectares, are suitable for SFA infill development and do not provide demonstrable
public recreational or amenity value, nor is there funding identified within the Local Plan evidence base
for the long term management and maintenance of this land as open space. The designations lack
robust justification as the sites were not assessed within the Council's Open Space Report (2023),
rendering the approach unsound.
We highlight that there is an urgent need in Colchester to deliver new SFA, yet the Local Plan provides
no recognition or policy support for this requirement contrary to national defence priorities set out in
NPPF Paragraph 102b. We also recommend inclusion of a specific Military Establishments policy to
support development that enhances operational capability and recognise SFA provision as essential
workers housing.
Key Requested Revisions
We respectfully request the following amendments to strengthen the Plan's deliverability and
soundness:
1. Remove Strategic Biodiversity designations from operational defence land (Land South
of Birch Brook and DIO Berechurch).
2. Remove Local Green Space designation from Middlewick Ranges to avoid policy
duplication and given it is an extensive tract of land and therefore unsuitable.
3. Remove Open Space designations from SFA estate land or provide policy flexibility for
SFA development.
4. Include specific policy recognition and support for general defence requirements and
Service Family Accommodation provision.
5. Incorporate greater flexibility and contingency planning within the spatial strategy.
6. Diversify housing supply through a broader range of site sizes and locations.
7. Establish clear triggers for releasing reserve sites to maintain housing supply
resilience.
Conclusion
The DIO remains committed to working collaboratively with Colchester City Council to ensure the
emerging Local Plan provides an appropriate and flexible framework that recognises both local
housing needs and national defence priorities. Our representations seek to strengthen the Plan's
effectiveness, deliverability, and resilience whilst ensuring that essential defence operations can
continue without unnecessary policy constraints.
We believe that addressing these concerns will result in a more robust and sounder Local Plan that
better serves the needs of Colchester's communities whilst fulfilling the Council's obligations to support
national defence requirements.
We look forward to your consideration of these matters and to continued engagement throughout the
Local Plan process.

Site specific allocation PP14 covers a variety of land parcels and sites that are adjacent to one another, but we are concerned that it will be very difficult for the policy to be truly delivered in a meaningful manner due to the land ownership arrangements and no mechanism within the policy for the site to come forward in a piecemeal manner.

We have attached our detailed response for the site.

We write on behalf of our client, [NAME REDACTED], in response to the Council's latest Regulation
18 consultation (November 2025). The current consultation starts to identify the Council's preferred options for growth, including identifying site allocations to meet housing needs.
[NAME REDACTED] has land interests in Langham, adjoining Park Lane to the south, with School Road to the north and Wick Road to the east (see Appendix A). The Site, measuring circa. 8 hectares, forms part of an identified allocation through Policy PP37 (Land North of Park Lane) as a preferred option for residential development.
Notwithstanding [NAME REDACTED] specific land interests, this response has been prepared in objective terms, in response to the current consultation and the supporting evidence base.
Response to Regulation 18 Consultation

Vision for Colchester

The overarching vision for the emerging Plan seeks to improve the quality of life for communities, create a better environment and contribute to healthy lifestyles. Emphasis is placed on the maximising opportunities through well connected green networks, as well as preserving and enhancing Colchester's identity. The main themes of the Local Plan vision include healthy and diverse places, welcoming inclusive communities, being well-connected and being sustainable. These themes are supported by a range of objectives, together forming a framework for how the vision of the Plan will be achieved.

Throughout the vision, its objectives and aims there is a common theme of supporting development which addresses needs and creates great places to live, work and play, whilst aiding the transition to net zero.
We support the vision identified by the Council, which can best be achieved through the adoption of an up-to-date Local Plan which seeks to meet housing and other growth needs in full in sustainable locations across the District.
Housing Needs and Requirements

Paragraph 62 of the NPPF states that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method. This further identifies that in addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.

The Council correctly identify the starting point for calculating minimum housing needs is the Standard Method (2024). This requires across the Plan period 2025 - 2041, the delivery of 20,800 homes, as a minimum. We support the acknowledgment that the Standard Method is a starting point for considering the housing requirement, this is justified and consistent with the NPPF.

Through the Sustainable Appraisal Report (SA, February 2025), the Council has determined there are no exceptional circumstances which justify a lower housing need. We consider this position is justified.
The Council has also established through the SA and Housing Topic Paper (November 2025) that there is no justification of increasing housing needs as a result unmet needs of neighbouring authorities or based on economic growth aspirations or infrastructure ambitions.

However, the Local Housing Needs Assessment (LNA, September 2024) highlights, based on the previous Standard Method, there is a considerable affordable housing needs of 877 affordable homes per annum. This affordable need is now likely greater reflecting the increase in minimum housing needs. The LNA concludes that affordable housing delivery should be maximised where opportunities arise. This is not considered in the SA with it instead concluding "that in the absence of the wider evidence justifying a lower, or higher level of growth, variation of the Standard Method requirement is not justified".

We consider further work should be completed by the Council to establish whether an increase in the housing requirement is achievable.

Plan Period

Para 22 of the NPPF is clear that strategic policies should look ahead over a minimum 15- year period from adoption. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.

The new Local Plan proposes a Plan period from April 2025 to March 2041, i.e. 16-years with the final monitoring year being 2040/41. This would require the Plan to be adopted before end of March 2027. This is considered unlikely on the basis of the Council's current Local Development Scheme.
We recommend the Plan period be extended by 2 years to ensure the required 15-year period post adoption is achieved, in order to avoid any soundness issues.

Spatial Strategy

The Plan identifies a proposed spatial strategy indicating this provides the framework for how the housing and employment needs will be metthrough allocations.
The Council's chosen hierarchy directs growth first to the urban area of Colchester, as the most sustainable location in the Plan area. Following this, it prioritises the growth and opportunity areas and then the most sustainable and accessible locations close to transport corridors and existing centres. This includes an "appropriate level" of growth allocated within the large, medium and some small settlements.
The settlement hierarchy remains an important part of the Plan, ensuring development can come forward in a sustainable manner whilst maximising the potential of the most sustainable settlements. This is consistent with the NPPF which states policies and decisions should guide development towards sustainable solutions, and states significant development should be focused on locations which are or can be made sustainable.
We are supportive of the approach to direct growth to the sustainable locations, notably those on or close to the main A road routes which cross through the District. The Council however needs to ensure sufficient justification is provided to support its distribution of development between settlements, including how the presence (or absence) of services and facilities have influenced this and proximity to transport corridors. For the reasons
as set out below, we consider the preferred options for Langham have been robustly justified.

The Plan should include a housing trajectory which identifies when sites are expected to deliver homes, ensuring housing needs are achieved across the Plan period including in the short (next 5-years) and medium (5 -10 years) periods.

Langham

Langham includes two areas of settlement, Langham Moor and St. Margaret's Cross, linked by School Road. Langham contains a primary school, public house, a community cafe, a community shop, community centre, recreation ground, a playground, football pitches and tennis courts. It lies close to the A12 trunk road and is highly accessible via the road network to Colchester and other hubs nearby. The village is located outside of the Dedham Vale National Landscape which is to the north and east. The village is therefore well placed as an existing sustainable settlement with capacity to grow.
The SA acknowledges this, confirming that Langham is a sustainable settlement. The SA, Plan and wider evidence base classifies Langham as a medium settlement. We support this view.
Not only does Langham already have a good range of facilities and services, but this and other infrastructure requirements (i.e. junction improvements) can be supplemented through development.
The Colchester Settlement Evidence Stage 2 (Oct 2025) illustrates the existing and preferred options for settlement boundaries, and for Langham it is proposed to extend this to include land to the north of Park Lane joining the two settlements. We are supportive of this change as it is a logical extension providing new sustainable links between the separate parts of the village.

The Site and Land North of Park Lane

The Site (Appendix A) abuts the existing settlement edge of Langham along its northern boundary, and is within close proximity along its eastern boundary. Residential properties are located to the east along Wick Road, as well as to the north along School Road/St. Margarets Cross, where the pre-school, primary school, post office, football club, tennis courts and community centre are also located (all of which are within walking distance of the Site).

Land directly to the north of the Site has recently been developed for 46 dwellings and associate public open space through application ref. 191830. Land to the west of the Site comprises agricultural land but is part of the same proposed allocation.

The Site, as a discreet parcel on its own (circa. 8 hectares), has capacity to support circa. 150 - 200 homes within vehicular access to be taken from Park Lane. Pedestrian and cycle access could be provided to the north, through the new development which includes a link to the public right of way which runs along (inside) the northern boundary of the Site. This will help ensure sustainable movement is prioritised, with future residents being able to easily and directly walk to the existing facilities of the village.

The Council's evidence base, through the SLAA and Summary of Sites Evidence (October 2025) assesses the Site as part of the much larger Land north of Park Lane, Langham proposed allocation (ref. 10664 / PP37). The Site has not been assessed on its own.

The assessment concludes the proposed allocation area is a suitable location for residential development. Whilst some potential constraints are identified, these can be readily addressed through design or mitigation, these do not affect deliverability. Further, there are no known overriding constraints with respect to utility / service provision, neighbouring uses, or landscape or nature conservation. The Site and wider allocation are wholly located within Flood Zone 1 and not located within a Critical Drainage Area.

Whilst the Infrastructure Delivery Plan (and associated Evidence Base) identifies existing foul drainage capacity constraints locally for Langham, this highlights there are likely to be solutions in place for this in the medium term. Alongside this, work is being undertaken to consider any other potential on-site or off-site solutions. We expect there will be deliverable and viable options to enable delivery on the Site in the short-term.

We therefore consider the Council's assessment of the Land north of Park Lane to be sound. We therefore support the identification of this land as a proposed allocation through Policy PP37. Nevertheless, it should be noted we consider the conclusions would equally apply to the Site on its own.

Policy PP37 (Land North of Park Lane) identifies the Site and wider land to the west to deliver approximately 900 new dwellings to include safe and suitable access in a location to be agreed with impacts, including on the strategic highway network and other infrastructure, to be satisfactorily mitigated. We consider this is readily achievable, and the allocation can deliver high-quality new development which aligns with the Council's aspirations. We consider a scheme could be designed sensitively which respects the character of the area and would not be significantly harmful to the wider landscape, including the nearby National Landscape.
The Policy identifies that proposals for the site will only be supported where they accord with a comprehensive masterplan in relation to the entire allocation, which has been agreed with the Council prior to submission of any planning application. Whilst we will seek to work collaboratively with the promoter of the land that forms the remainder of the allocation, we consider the Site could come forward separate to the wider allocation. It forms a discreet parcel adjoining the existing settlement boundary, with clear and obvious links to the south (via road) and north (via pedestrian routes). The ability for delivery to be achieved on the Site in the first 5-years of the Plan may be undermined if there are delays associated with the larger remainder of the allocation to the west. The policy wording should be tweaked to allow for the Site to come forward separately so long as it does not undermine the ability of the wider allocation to deliver a high-quality development.

Summary and Next Steps

As set out in these Representations, whilst further work should be undertaken to fully justify the approach proposed we support the Council's aspirations to proactively plan for growth, through the adoption of an up-to-date Plan. We look forward to discussing this further with the Council in due course, and are happy to provide any further information which may assist in the Council's ongoing consideration of the Site as part of this Plan-making process.

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.