Mersea island is flooding when it rains as due to over building and taking away the natural flood planes so more building will cause more flooding

support if placed in discreet manner blending with authentic TA

Mersea Island's drainage system is already not fit for purpose. Increasing number of houses being built will increase the number of people using the drainage system and not sustainable

The limited public transport serving the Island is regularly affected by the high tides on the Strood.

Tidal flooding of the road greatly impacts access on and off the Island.

The area along moor road and chapel road has been flooded in the past. Insurance companies have this flagged as a flood risk area. The flooding was caused by Anglia Water equipment failing (which there management deny) and the over capacity of the present treatment plant.
The present ditch system in the village has not been maintained for many years and is not fit for purpose. If 900 houses are built the increased surface water will only compound the already existing problem of flooding and over capacity of the Langham Water Recycling Centre.

The map as shown is totally inaccurate as to flooding events - there have been no flooding events on our property. Why aren't residents consulted in this respect?

Deference should be paid to EN8, particularly "Planning permission will only be granted where it has been demonstrated that: ... flood risk will not increase on or off site as a result of the development.".

As mentioned elsewhere, any development reliant on Tiptree Sewage Works processing that does not include pro rated processing to prevent increased run-off to Salcott would violate this as it would increase flood risk in Salcott.

No development north of A120 (PP18) before the A120 has first been fully upgraded

The proposal to develop land north of the A120 in Marks Tey will inevitably generate large quantities of surface water (from roofs and highways) very quickly and drain into Roman River. My property ()[REDACTED] lies within the historic & designated flood zone of Roman River (downstream of development) and I fear that the flood zone will enlarge and engulf my property. The development must include flood ponds to slow down the drainage of the development in heavy rainfall to avoid flooding my home and making it uninsurable.

West Bergholt Parish Council supports this policy.

The requirement in criterion (f) for SuDS to be multi-functional and provide aesthetic and amenity value and safe public access is welcomed. SuDS can provide a recreational resource in new developments and if appropriately designed can encourage people to visit them as a recreational destination by active travel modes thereby encouraging physical activity in close proximity to where people live and work.

Essex Wildlife Trust welcomes the opportunity to respond to the Colchester Local Plan Preferred Options
(Regulation 18) consultation. Our response focuses on the environmental policies within the draft Plan, assessed
against current legislative requirements and national policy, including the Environment Act 2021, the National
Planning Policy Framework (December 2024) (NPPF), the Conservation of Habitats and Species Regulations 2017
(the Habitats Regulations), the Wildlife and Countryside Act 1981 (as amended), the NERC Act 2006 and the
Essex Local Nature Recovery Strategy (Essex LNRS).
1. Overall Assessment
Overall, the draft Plan provides a good framework for protecting and enhancing Colchester’s natural environment.
The policies align with statutory requirements under the Environment Act 2021, the Habitats Regulations, the
Wildlife and Countryside Act and the NERC Act 2006. The integration of the Essex LNRS throughout the policies is
welcome and provides a mechanism for coordinating nature recovery efforts at the local level.
Policy EN1 on Nature Conservation Designated Sites provides robust protection for internationally and nationally
designated sites, with clear provisions for the Essex Coast Recreational disturbance Avoidance and Mitigation
Strategy (RAMS). Policy EN3 on Biodiversity and Geodiversity is comprehensive in scope, covering designated
sites, protected species, Priority Habitats and Species, and habitats of local importance, and the policies relating
to the Green Network and Waterways establish a strategic framework for multifunctional green infrastructure.
However, our assessment has identified one key strategic omission and several areas where policies could be
strengthened to align fully with the most recent national policy updates and government biodiversity
commitments. These are set out in detail below.
2. Key Strategic Omission: The 30x30 Target
The most significant gap we have identified is the absence of any reference to the UK Government’s commitment
to protect 30% of land for nature by 2030, known as the 30x30 target. This is a critical strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage.
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At the UN Biodiversity Summit COP15 in December 2022, the UK Government formally committed to protecting
and conserving a minimum of 30% of land and sea for biodiversity by 2030. This commitment was reinforced
domestically, with Defra publishing delivery criteria and a map in December 2023 setting out what should count
towards the 30x30 target in England. The target has been further emphasised through the UK’s National
Biodiversity Strategy and Action Plan published in February 2025, which outlines how the UK will meet all 23
Global Biodiversity Framework targets, including 30x30.
The 30x30 target is not merely aspirational; it is a central pillar of the UK’s biodiversity strategy and a key driver for
reversing nature decline. Local Plans have an important role in contributing to this national commitment by
identifying how growth and development will support, rather than undermine, the expansion and improvement of
protected areas and other effective area-based conservation measures.
The draft Plan identifies “strategic biodiversity areas” which present the best opportunities for habitat creation and
enhancement. Policy GN2 provides explicit support for delivering the Essex LNRS and identifies the Roman River
corridor as a nature recovery area. Policy EN2 identifies four strategic offsite Biodiversity Net Gain sites. These
policies directly support nature recovery objectives but make no reference to how this contributes to the 30x30
target.
Recommendation: We recommend that explicit reference to the 30x30 target is incorporated into Policy ST2
(Environment and the Green Network and Waterways), Policy GN2 (Strategic Green Spaces and Nature Recovery),
and Policy EN2 (Biodiversity Net Gain and Environmental Net Gain). This would demonstrate how the Local Plan
contributes to this important national commitment and provide a clear strategic context for the delivery of nature’s
recovery in Colchester.
3. National Planning Policy Framework December 2024 Updates
The National Planning Policy Framework was updated in December 2024 and includes specific new requirements
that should be reflected in the Plan. Paragraph 187(d) now explicitly requires planning policies and decisions to
minimise impacts on biodiversity and provide net gains, “including by establishing coherent ecological networks
that are more resilient to current and future pressures and incorporating features which support priority or
threatened species such as swifts, bats and hedgehogs.”
While the draft Plan includes comprehensive biodiversity policies, the specific reference to swifts, bats, and
hedgehogs in national policy should be explicitly reflected in local policies. These species face particular threats
from development, and incorporating specific features to support them (such as swift bricks, bat boxes, and
hedgehog highways) represents best practice in biodiversity enhancement.
Recommendation: We recommend that Policy EN3 (Biodiversity and Geodiversity), Policy ST8 (Place Shaping
Principles), and Policy GN1 (Open Space and Green Network and Waterways Principles) are updated to explicitly
reference the requirement to incorporate features supporting priority and threatened species, with particular
attention to swifts, bats, and hedgehogs as identified in national policy.
4. Policy EN2: Biodiversity Net Gain and Ambition
Policy EN2 correctly acknowledges that Biodiversity Net Gain is now a mandatory statutory requirement under the
Environment Act 2021, with development required to deliver a minimum of 10% BNG. The policy appropriately
focuses on maximising onsite delivery and identifies four strategic offsite BNG sites with high strategic significance
for biodiversity. This approach is sound and well-justified.
However, we note that the policy focuses on delivering the statutory 10% minimum without exploring whether a
higher percentage of BNG would be required to achieve the strategic habitat creation objectives set out in the
Essex LNRS. The Essex LNRS aims to significantly increase habitat coverage across the county. There is a
question as to whether the cumulative delivery of multiple development schemes each achieving 10% BNG will be
sufficient to meet these more ambitious habitat creation targets, or whether higher BNG percentages should be
encouraged in strategic locations.
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We recognise that BNG requirements are delivered through separate statutory mechanisms and do not need to be
repeated in planning policy. However, the Plan could be strengthened by encouraging developers to explore
opportunities for higher percentages of BNG delivery where this would support delivery of Essex LNRS habitat
creation priorities and contribute to nature recovery objectives.
Recommendation: We recommend that Policy EN2 is revised to clarify the relationship between statutory BNG
requirements and the Plan’s strategic approach to BNG delivery, and to encourage BNG delivery beyond the
statutory minimum where this would support Essex LNRS priorities. We also recommend that the policy includes
reference to how strategic BNG delivery contributes to the 30x30 target.
5. Climate Change Adaptation
The NPPF December 2024 includes updated provisions on climate change, with paragraph 163 requiring planning
applications to address the “full range of potential climate change impacts.” The draft Plan includes references to
climate change throughout the environmental policies, and Policy EN8 on Flood Risk and Sustainable Drainage
Systems provides comprehensive provisions for climate adaptation in the context of water management.
However, the integration of climate adaptation measures into biodiversity and habitat creation policies could be
strengthened. Climate change is placing increasing pressure on habitats and species, and nature recovery efforts
must consider long-term resilience to changing climatic conditions. This includes consideration of climateappropriate species selection, habitat design that anticipates future climate conditions, and measures to enhance
the climate resilience of designated sites and their supporting habitats.
Recommendation: We recommend that climate adaptation provisions are strengthened across the
environmental policies, with particular attention to Policy EN3 (Biodiversity and Geodiversity), Policy EN4
(Irreplaceable Habitats), and Policy EN5 (New and Existing Trees). This should include requirements for climateadapted habitat creation and species selection that considers future climate projections.
6. Specific Policy Comments
Policy EN1: Nature Conservation Designated Sites
This policy provides robust protection for designated sites and complies with the Habitats Regulations. The
integration of the Essex Coast RAMS is comprehensive, and the innovative provisions for nature-based welcome
packs for large developments are welcomed.
Policy EN3: Biodiversity and Geodiversity
This is a comprehensive policy covering a range of biodiversity interests including designated sites, protected
species, Priority Habitats and Species, and habitats of local importance. The policy properly requires application
of the mitigation hierarchy and includes provisions for Local Wildlife Site buffering. The reference to the “creating
space for nature” design principles in the Biodiversity Supplementary Planning Document is helpful, although the
Council should ensure that the SPD is adopted in a timely manner or that the policy provides sufficient standalone
guidance if the SPD is delayed.
Policy EN4: Irreplaceable Habitats
This policy provides protection for irreplaceable habitats in compliance with the Biodiversity Gain Requirements
(Irreplaceable Habitat) Regulations 2024 and NPPF paragraph 186(c). However, the policy’s approach to buffer
zones requires strengthening. While the policy correctly identifies a 15-metre buffer zone for ancient woodland
and acknowledges that larger buffer zones may be required where surveys show impacts extending beyond this
distance, Natural England guidance is clear that 15 metres represents the minimum requirement for a root
protection zone only. Buffers may need to be significantly increased depending on multiple factors including
development type, the nature and extent of impacts, and the particular sensitivities of protected species
associated with the woodland.
Ancient woodlands support specialist and sensitive wildlife that can be affected by development impacts well
beyond the 15-metre root protection zone. These impacts include noise disturbance, light pollution, domestic pet
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predation (particularly from cats), recreational pressure from residents, and edge effects such as increased wind
exposure and changes to microclimate. For example, ground-nesting birds such as nightingales require buffers
sufficient to protect them from disturbance, while bat populations may be affected by artificial lighting many tens
of metres from woodland edges. Buffer zones must therefore be designed to address the full range of potential
impacts on both the habitat itself and the species it supports, not merely to protect tree roots.
Recommendation: We recommend that the policy is strengthened to make clear that 15 metres is the minimum
buffer for root protection only, and that significantly larger buffers will be required to address the full range of
potential impacts including noise, light pollution, recreational pressure, and disturbance to protected species. The
policy should require applicants to assess all potential impacts and design buffer zones accordingly, with clear
justification required where buffer widths are proposed. Additionally, the justification text would benefit from
clarification that loss of irreplaceable habitats requires bespoke compensation in addition to any Biodiversity Net
Gain requirements that apply to the remainder of a development site, and that off-site biodiversity units and
statutory biodiversity credits cannot be used to compensate for the loss of irreplaceable habitat.
Policy EN8: Flood Risk and Sustainable Drainage Systems
This policy provides strong coverage of flood risk management and sustainable drainage, with a welcome
emphasis on nature-based solutions. The requirement for multifunctional SuDS that enhance biodiversity and
provide amenity value is strongly supported. The policy would benefit from explicit clarification that SuDS features
can contribute to Biodiversity Net Gain delivery, and where they do so, they must meet the 30-year habitat
management and monitoring requirements of the BNG regulations.
Policy GN2: Strategic Green Spaces and Nature Recovery
This policy provides strong support for delivering the Essex LNRS and identifies the Roman River corridor as a
specific nature recovery area. This strategic approach to landscape-scale nature recovery is welcome. However,
as noted above, the policy would be significantly strengthened by explicit reference to the 30x30 target and how
strategic green space and nature recovery delivery in Colchester will contribute to this national commitment.
Policy GN4: Tree Canopy Cover
The requirement for a 10% tree canopy cover target for major applications is supported. We note that the
justification text references research concluding that an average tree canopy cover of 20% should be set as the
minimum standard for most UK towns and cities. While we recognise the practical challenges of achieving higher
targets, we encourage the Council to review whether a more ambitious target could be appropriate for Colchester,
particularly given the multiple benefits that trees provide for biodiversity, climate adaptation, air quality, and
human health and wellbeing.
7. Essex Wildlife Trust’s Biodiversity Net Gain Proposals
Essex Wildlife Trust welcomes the identification of our proposals at Abbotts Hall Farm, Great Wigborough as one
of the Council’s preferred strategic offsite BNG sites in Policy EN2. As set out in the policy justification, the
creation of a BNG habitat bank at Abbotts Hall will contribute to the Trust’s wider ambitions to rewild the site and
establish a nature reserve, which will be open to the public in 2026. The site is strategically significant, being
adjacent to the Blackwater Estuary SPA, Ramsar and SSSI and the Essex Estuaries SAC, while also connected to
other coastal nature conservation sites including Old Hall Marshes (RSPB) and Copt Hall (National Trust).
Proposed habitats at Abbotts Hall include lowland mixed deciduous woodland, ponds, medium distinctiveness
scrub, individual trees, species-rich native hedgerow, grassland, ditches, and saltmarsh. There are opportunities
for extensive habitat creation on formerly cultivated fields including grassland, wetland and woodland. Habitat
creation measures will integrate with adjacent and nearby internationally designated sites and will prioritise locally
relevant species including Nightingale and Turtle Dove.
The Trust is committed to working with the Council to deliver high-quality biodiversity net gain through this site,
ensuring that development in Colchester makes a meaningful contribution to nature’s recovery at a landscape
scale.
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8. Conclusion
The draft Regulation 18 policies generally align with current statutory requirements and overall provide an
acceptable framework for protecting and enhancing the natural environment. The integration of the Essex LNRS
throughout the Plan is particularly welcomed and should provide an effective mechanism for coordinating local
nature recovery efforts with county-wide objectives.
However, the absence of any reference to the UK Government’s 30x30 target represents a strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage. The 30x30 commitment is a central
pillar of the UK’s biodiversity strategy and Local Plans have an important role in demonstrating how growth and
development will support, rather than undermine, the achievement of this national target.
We also recommend that the Plan is updated to explicitly reflect the requirements of the NPPF December 2024,
particularly the specific provisions relating to priority and threatened species such as swifts, bats, and hedgehogs.
Climate adaptation provisions could be strengthened across the environmental policies, and Policy EN2 would
benefit from greater ambition in encouraging BNG delivery beyond the statutory minimum where this would
support Essex LNRS priorities. Policy EN4 requires strengthening to clarify that 15 metres is the minimum buffer
for tree root protection, and that significantly larger buffers around ancient woodlands may be required to address
the full range of potential impacts.
Essex Wildlife Trust looks forward to continuing to work constructively with Colchester City Council as the Local
Plan progresses through the plan-making process. Should you require any clarification on the points raised in this
response, or wish to discuss any aspect of nature conservation and recovery in Colchester, please do not hesitate
to contact us.

To be justified and effective, EN8 should:
· Make clear that winter groundwater monitoring will only be required where initial evidence indicates a realistic risk that groundwater will constrain SuDS; and
· Confirm that, for lower-risk allocated sites, an FRA and SuDS strategy proportionate to the scale and risk profile of the development will satisfy the policy.

Without such clarification, EN8 risks adding unnecessary cost and delay to allocated housing sites, contrary to the plan’s housing delivery objectives.

The Councils view of Marks Tey as a sustainable location for development and the allocations under policies PP17 and PP18 are supported, however, we do have some concerns particularly in relation to the level of development that can be achieved within the plan period in light of the significant infrastructure improvements that are required for development of this scale, and which can often take some time to work through. This needs to be taken into consideration. In this regard it is suggested that alongside the extension of the plan period further allocations are required at Marks Tey in the short-term.

Policy EN8 as drafted is overly lengthy, highly prescriptive and in places duplicates national policy, guidance and technical standards. As a result, it risks reducing flexibility, increasing development costs and creating uncertainty in development management, without clear additional local benefit.

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

Policy EN8 seeks to avoid new development within areas of flood risk in accordance with the national policy guidance. It is noted that this general approach continues that of adopted Local Plan Policy DM23 and largely aligns with the NPPF. However, the policy appears unnecessarily wordy and overly onerous in parts without justification for such.
The policy states that planning permission will only be granted where it is demonstrated that a site will remain safe from all types of flooding throughout the lifetime of the development. This wording is not consistent with national guidance in the NPPF (Dec. 2024, paragraph 170). The NPPF requires applicants to demonstrate that development within areas of higher flood risk will be appropriately flood-resilient and safe, but it does not require an absolute guarantee of safety from all flood sources in all circumstances over the lifetime of a development. Assessments of flood risk should be proportionate and evidence-based with mitigation secured where justified.
As drafted, the policy could be interpreted as imposing a zero-risk requirement, which is neither realistic nor supported by national policy. To ensure alignment with the NPPF, it is therefore recommended that the wording is amended to reflect the national test of ensuring development is safe for its lifetime without increasing flood risk elsewhere, rather than requiring absolute safety from all sources.
The policy states that:
"Where sites are at risk of groundwater flooding, construction phase groundwater monitoring during periods of high groundwater (October – March) should be included in the Flood Risk Assessment to inform the design and any mitigation measures, unless adequate justification can be provided by the applicant to exempt the proposed development from this requirement".
While the need to assess groundwater risk in certain circumstances is recognised, it is not realistic to require construction phase groundwater monitoring to be included within a Flood Risk Assessment submitted at the planning application stage, as monitoring can only be undertaken during the construction phase. We therefore recommend that the proposed policy wording be amended either to remove the reference to requiring construction-phase groundwater monitoring, or reworded as follows:
"Where sites are identified to be at risk of groundwater flooding, the Flood Risk Assessment submitted with the planning application should identify and assess the potential for groundwater impacts and, where appropriate, include a proposed construction-phase groundwater monitoring scheme to inform any required mitigation measures".
The policy further states that:
"Development must conserve and enhance the natural flood storage value of the water environment, including watercourse corridors and catchments".
The wording must conserve and enhance is considered overly onerous and not consistent the language used in the NPPF. There may be circumstances where it may not be possible to enhance the water environment. A more proportionate and flexible approach would be: 'Development proposals must conserve and, where possible, enhance the natural flood storage value of the water environment…'. This better aligns with the language of the NPPF.

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

Hopkins Homes are pleased to see that the Council has identified the land north of
Colchester Road as a site-specific allocation and included Policy PP43 within the Preferred
Options consultation draft.
We agree with the Council that the site is a suitable location for future residential
development and can be delivered within the plan period to make a significant contribution to
housing delivery and meeting the housing needs of Colchester.

Please see attached document for the rest of our representations.

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.

see attached

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.

National Highways welcomes the opportunity to provide comments on the 'draft Local Plan 2041 or the 'Preferred Options' for Colchester.

National Highways has been appointed by the Secretary of State for Transport as a Strategic Highway Company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network(SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery part to national economic growth.

Within this area the SRN comprises of the A12 and A120 between the A12 and the port of Harwich.

In responding to local plan consultation, we have regard to Dft Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (the Circular) which sets out how interactions with the Strategic Road Network should be considered in the making of local plans.

In addition to the Dft Circular 01/2022 the response set out below is in accordance with the National Planning Policy Framework (NPPF) and other relevant policies.

Based upon our initial review of the reports and other supporting documents available to us we have identified the items below, where we require further information and or clarification to help in completing our review of the draft plan.

The plan commits to the delivery of approximately 20,800 homes and 41.7Ha of employment land over the plan period.

At present, based upon our review, National Highways is unable to determine whether the level of growth proposed can be accommodated on the SRN, as the transport evidence base and the Strategic Transport Assessment which support the plan are still being developed. While we have been involved in a number of meeting and discussions to date,, these have not yet reached a conclusion

It is anticipated that a final transport evidence base will be submitted in support of the plan. The provision of a robust transport evidence base will allow National Highways to work alongside the Local Highway Authorities using a clear and defined Reference Case. This will support the planning of mitigation measures to address the impacts of future developments, enable infrastructure delivery to support growth and identify appropriate mitigation alongside a strategy for funding.

Notwithstanding the above, work undertaken to date indicates that a number of locations on the SRN are already under stress, with particular concern at A12 junctions 25,26,28 and 29. In addition, sections of the main line are forecast to operate close to capacity during the plan period. A strategy to address these issues is currently being developed. National Highways also has concerns that the trip rates applied within the model may be optimistic and therefore could underestimate the impact of the Local Plan on the highway network. We note that not all forecast growth arises from the proposed Local Plan and that network conditions would remain challenging even in the absence of the Plans growth.

The work to date has assessed two scenarios, including one incorporating the A12 J19-J25 DCO improvement scheme, the funding for which was formally withdrawn in the summer of 2025. This change has necessitated a review of the Local Plan and its supporting evidence.

We welcome and fully support the Plans commitment to the delivery of an integrated and sustainable transport network, including measures to encourage modal shift to public transport and active travel. We recognise, however, that achieving a meaningful reduction in car dependence will be challenging. We welcome the commitment to Bus Rapid Transit, and emphasise that if development within the Plan is to come forward in a sustainable manner, the timing and coordinated delivery of development supporting infrastructure will be critical, noting that this remains a significant challenge for plan led growth.

Environmental transformation and climate change

It is noted that the submitted draft Local Plan and the identified site allocations will increase the number of residents living in close proximity to the SRN. As a result, it is likely that these locations will experience increased exposure to noise pollution from the SRN. National Highways will not support the provision of noise barriers located on its land as part of mitigation proposals.

The close proximity of development to the SRN also raises the potential for exceedances of air quality standards for which extraordinary measures such as a

permanent speed restriction may need to be considered. While it is acknowledged that air quality is expected to improve over time with the increasing uptake of fully

electric vehicles, this cannot be relied upon as the sole mitigation measure during the plan period.

Although several polices within the local plan require development to reduce Impacts on or improve local air quality, these provisions do not clearly address impacts arising specifically from the SRN, nor do they set out how any required mitigation would be identified and delivered. We will continue to work proactively with yourselves on these matters, however, we would recommend the inclusion of a specific policy mechanism that clearly identified:

how air quality and noise impacts associated with the SRN will be assessed and monitored: and
The range of potential interventions that may be required should adverse impacts be identified.

In addition, National Highways will not accept third party connections into its drainage systems. Development proposals must ensure that no additional surface water run off is discharged to the SRN drainage network Where necessary, drainage capacity will need to be fully assessed and upgraded by the developer to ensure no adverse impact on the SRN.

Health and Wellbeing

We support the policies which set out requirements for new developments to deliver inclusive, active and environmentally sustainable modes of travel, including measures to promote road safety and to manage the negative effects of road traffic on sustainable modes. We look forward to continuing to work collaboratively with you to facilitate such travel particularly where there is an an interface with the SRN .

Lorry Parking

Lorry parking is a national problem, with particular pressures evident in East of England. National Highways would therefore welcome the investigation and allocation of a dedicated lorry parking facility within the Local Plan, ideally located in close proximity to the SRN. Where this is not achievable we would support the inclusion of a policy requirement for adequate lorry parking and overnight layover facilities to be provided as part of proposed employment sites and roadside service facilities. For context, we enclose a copy of AECOM report dated June 2019 (Appendix 2) which sets out the background evidence underpinning this request

Eight Ash Green and Copford,

National Highways is willing to work with the council and developers to explore opportunities to bring these sites forward. However, A12 J26 is currently operating very close to capacity and options for physical highway improvements at this location are extremely limited. The acceptability of development at this junction will therefore depend on whether queues on the slip road can be effectively managed to prevent interference with the A12. If this risk cannot be adequately mitigated, National Highways reserve the right to object to development at these sites, on the basis that it could give rise to a severe highway safety concern.

Marks Tey

The Plan identified three large site allocations. While the level of development proposed within the plan period does not represent the full quantum of development promoted for these sites, the principal of significantly larger scale development is established through allocation. Capacity on both the A12 and A120 is extremely constrained, and these corridors are not capable of accommodating additional growth without significant intervention. While it is acknowledged that Local Plan growth is only one contributory factor to existing and forecast congestion, there are currently no proposals for capacity enhancements on either route

Furthermore, development in close proximity to these corridors constrains opportunities for future improvements, particularly in the vicinity of A12 Junction 25, where land availability and operational flexibility is limited.

National Highways remains committed to continue to work with your authority in a collaborative and constructive manor to support the progression of the plan. We will continue to work with you to develop a clearer understanding of the impacts of proposed development upon the SRN and to explore whether, and how, such impacts could be accommodated.

We trust the above comments are helpful in informing the progression of your proposals and welcome continued engagement and discussion with the council on these matters.