full economic use on the ground should be supported to justify this- many non-polluting ways to achieve this without real pollution, i.e.. chemicals, etc.

Here again alternative SANG’s should not be put upon Mersea unless directly belonging to development on Mersea Island.
& EN2 4.8 Natural England consider that Maydays Farm would provide an excellent opportunity to create valuable habitat for wading birds and enhance habitat connectivity. The site is a strategic location, adjacent to the Colne Estuary SSSI. The land is entirely below 5m AOD and adjacent to Pyefleet Channel making it suitable for the creation of grazing marsh and associated freshwater habitats. It would also be suitable for the creation of intertidal habitats, although they are currently outside the remit of BNG.

I am commenting on Policy PP23 because West Mersea cannot support further large‑scale development. The B1025 is the only route on and off the island, and regular tidal closures at The Strood restrict safe, reliable access for residents, services and emergency responders. Healthcare provision is already stretched, and wastewater infrastructure is at or near capacity. Mersea is surrounded by nationally protected designations (SSSI, SPA, SAC, Ramsar, MCZ) which require stronger safeguards. Policies ST1, ST2, ST7, EN1 and LC1 must be applied more robustly. Development at Dawes Lane is not sustainable without addressing these constraints.

See attached submission.

Colchester Local Plan
Regulation 18
Land Northwest of the Fire Station,
Wivenhoe
On behalf of
Manor Oak Homes and Mr Charles Gooch
January 2026
CONSULTATION
RESPONSE
TABLE OF CONTENTS
1. INTRODUCTION..........................................................................................................................................................1
2. THE SITE.......................................................................................................................................................................5
3. POLICY PP24...............................................................................................................................................................7
4. POLICY GN5, SUSTAINABILITY APPRAISAL AND EVIDENCE BASE.................................................................19
5. CONCLUSION ...........................................................................................................................................................24
Appendix A - Revised Site Plan (Red Line) – SLP-01 P4............................................................................................26
Appendix B – Recommended Amendments to Policy PP24...................................................................................27
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1. INTRODUCTION
Background
1.1 This representation is prepared on behalf of Manor Oak Homes and Mr Charles Gooch (the
Promoters) in respect of the Colchester City Council Preferred Options Local Plan Regulation 18
Consultation.
1.2 In January 2024 Ceres Property were instructed to make ‘Call for Sites’ submissions in respect of
three land parcels on the northern side of Wivenhoe (Site IDs: 10755, 10757 & 10756). The
submissions were accompanied by a Constraints and Opportunities Plan which was submitted in
support of potential development sites, and is reproduced at Figure 1 below.
Figure 1: Constraints and Opportunities Plan
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1.3 For Wivenhoe, Policy PP24 proposes to allocate Land Northwest of the Fire Station, Colchester Road,
Wivenhoe for approximately 175 homes. This is predominantly the southern land parcel shown on
Figure 1 above, and subject to some revisions and commentary as set out below, is the focus of this
representation.
1.4 This representation provides formal comments on the draft policies within the plan considered
relevant to our client’s interests, in particular Policy PP24.
1.5 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
principle of the inclusion of Policy PP24 in the Plan. They welcome the opportunity to work with
Planning Officers to further refine the Policy and ensure that the site is both a developable and
deliverable housing opportunity.
1.6 While they are obviously disappointed the other two land parcels have not been proposed as
allocations, we would like to confirm that they are both still available, either in their entirety or in
part for inclusion in the emerging plan, in the event further sites are required to meet the Council’s
substantial housing needs and ensure there is a sufficient supply of sites to do this over the plan
period.
Policy Context
1.7 In preparing these representations, regard has been had to the National Planning Policy Framework,
December 2024 (NPPF). Paragraph 11 of the NPPF sets out:
Plans and decisions should apply a presumption in favour of sustainable development.
For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet
the development needs of their area; align growth and infrastructure; improve the
environment; mitigate climate change (including by making effective use of land in urban
areas) and adapt to its effects;
b) 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, unless:
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i. the application of policies in this Framework that protect areas or assets of particular
importance provides a strong reason for restricting the overall scale, type, or distribution
of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the
benefits, when assessed against the policies in this Framework taken as a whole.…
1.8 Section 3 of the NPPF relates to ‘plan-making’. Paragraph 15 of the NPPF promotes a plan-led
system, and that succinct and up-to-date plans should provide a positive vision for the future of
each area; a framework for addressing housing needs and other economic, social and
environmental policies; and a platform for local people to shape their surroundings.
1.9 Paragraph 16 states that Plans should:
a) be prepared with the objective of contributing to the achievement of sustainable
development;
b) be prepared positively, in a way that is aspirational but deliverable;
c) be shaped by early, proportionate and effective engagement between plan -
makers and communities, local organisations, businesses, infrastructure
providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a
decision maker should react to development proposals;
e) be accessible through the use of digital tools to assist public involvement and
policy presentation; and
f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to
a particular area (including policies in this Framework, where relevant).
1.10 As set out at paragraph 36, local plans are examined to assess whether they have been prepared in
accordance with legal and procedural requirements, to determine whether they can be considered
‘sound’. The test for soundness as set out within the NPPF requires that Plans are:
a) Positively prepared
b) Justified
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c) Effective
d) Consistent with national policy
1.11 By way of background to the Council’s preparation of the emerging Local Plan, it is acknowledged
that the Council’s current five year land supply is increasingly marginal.
1.12 In February 2026 the existing Adopted Section 1 Local Plan becomes five years old, and the housing
requirement within it will accordingly be out of date for the purposes of calculation of five year
housing land supply as set by NPPF paragraph 232. At this point in time the Council accept that they
will be unable to demonstrate a five year housing land supply and this situation is unlikely to be
rectified until the adoption of the new Local Plan.
1.13 The housing land supply annual requirement will therefore become approximately 1,300 dwellings
per annum in line with the standard method, as opposed to 920 dpa within the existing adopted
Local Plan. Over a five year period this will add 1,900 homes to the required supply, plus the required
buffer.
1.14 The Council acknowledges this requirement at paragraph 3.36 of the Regulation 18 Consultation
document, confirming that the requirement for 20,800 new homes over the plan period is a
mandatory target (or minimum target [emphasis added] ) which must be planned for. At present
the draft Plan proposes to deliver 21,106 new homes which equates to a headroom of just 1.1%.
There is also a significant Affordable Housing need in the Borough, which the 2024 Housing Needs
Assessment indicates equates to 877 affordable dpa. Both these factors suggest that it is likely that
the Regulation 19 Plan will need to establish a higher total requirement figure, not only to provide
an appropriate buffer of a minimum 5% but also to boost overall numbers to help address acute
affordable housing needs.
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2. THE SITE
2.1 On 7th February 2025 the Council published papers for the Local Plan Committee meeting to be
held on 17th February which included a full draft of the Regulation 18 Preferred Options Local Plan
and the inclusion of Policy PP24. While at that time the resolution to publish the plan for consultation
was not agreed, the draft Plan sought to allocate sufficient sites to provide for 1,300 dwellings per
year across the new Plan period to 2041. For Wivenhoe, Policy PP24 proposed to allocate Land
Northwest of the Fire Station for approximately 175 homes.
2.2 As stated above, Manor Oak Homes and Mr Charles Gooch welcomed the proposed inclusion of the
Land Northwest of the Fire Station as an allocation in the emerging Local Plan. Having reviewed draft
Policy PP24, the Promoters have been working with their consultant team to progress further
technical work to help support the Site’s early delivery. Updated plans and technical notes/reports
have now been produced to provide further evidence to support the Site’s inclusion as both a
developable and deliverable opportunity. These confirm that, a development with the following
description could be brought forward;
A proposed residential development of approximately 200 dwellings with land for a new
community space, associated public open space, landscaping , and infrastructure.
2.3 A positive meeting with officers from the Council’s Planning Policy Team was held on 16th December
2025 to provide an update on the progress which has been made to date. The following documents
were provided to the Council ahead of the meeting:
• Revised Site Plan (Red Line) – SLP-01 P4: Produced by Thrive Architects
• Wivenhoe Constraints and Opportunities Context Plan – COP-01 P4: Produced by Thrive
Architects
• Concept Master Plan Option 1 – CMP-02 P7: Produced by Thrive Architects
• Concept Master Plan Option 2 – CMP-02 P8: Produced by Thrive Architects
• Land Budget Plan Option 1 – LBP-02 P7: Produced by Thrive Architects
• Land Budget Plan Option 2 – LBP-02 P8: Produced by Thrive Architects
• Proposed Access – 1255-TA11: Produced by Martin Andrews Consulting
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• Arboricultural Impact Plan – OE-002 October 2025: Produced by Origin Environmental
• Technical Note – Highways: Produced by Martin Andrews Consulting
• Indicative Attenuation Requirement – 1255-FRA03 Rev A: Produced by Martin Andrews
Consulting
• Technical Note – Flood Risk and Drainage: Produced by Martin Andrews Consulting
• Landscape & Visual Technical Note – October 2025: Produced by Aspect Landscape Planning
• Preliminary Ecological Appraisal – September 2025: Produced by Blackstone Ecology Ltd
2.4 Apart from the Revised Site Plan (Red Line) – SLP-01 P4 (at Appendix A) these have not been reprovided as part of the consultation response; however, further copies can be made available if
required.
2.5 Following the submission of this representation it is the Promoters intention to work up a formal
pre-application submission to help further develop the detail of site proposals ahead of the potential
submission of an outline application later in the year, which will help to confirm that the Site is
developable and provide a clearer indication of when housing delivery may actually commence.
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3. POLICY PP24
Supporting Text
3.1 The supporting text for Policy PP24 is set out at paragraph 12.24 of the draft Plan. This confirms that
Wivenhoe benefits from a good range of infrastructure including a mainline train station, GP surgery,
two primary schools, numerous shops and restaurants, and abundant open space provision. It also
benefits from public transport connections to Colchester and a good cycle and footpath network
which provides good connections to the University of Essex, amongst other destinations. As such,
the Town can be acknowledged as a sustainable location, in line with the Plans development strategy
for the accommodation of further growth.
3.2 Paragraph 12.24 also acknowledges there are a number of environmental constraints which
reasonably restrict the opportunities for the town’s expansion to the south, east, and west, which
confirms the only logical direction for some proportionate growth is to the north.
3.3 There is also a made neighbourhood plan for Wivenhoe, the Wivenhoe Neighbourhood Plan
(Adopted May 2019), which has helped to guide development in the past, whilst safeguarding the
surrounding environmentally sensitive areas. Whilst this is part of the Development Plan, it is now
over five years old and as such the weight which can be attributed to its policies will need to be
moderated to reflect the increased local housing requirement.
Policy PP24: Land Northwest of the Fire Station, Wivenhoe
3.4 The requirements of Policy PP24 are set out in turn below with comments and responses provided
to each of the relevant criteria. Overall, the allocation is supported with the proposal for
approximately 175 new homes, or more to make the most efficient use of the Site, considered
appropriate, given the sustainability of the settlement, and Wivenhoe’s position in the Borough’s
settlement hierarchy. There are, however, a number criteria within the Policy which it is considered
might be better worded, require clarification, or are not actually considered to be necessary to
enable the effective delivery of the allocation.


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Policy PP24: Land Northwest of the Fire Station, Wivenhoe
In addition to the infrastructure and mitigation requirements identified in Policy ST 7 and subject to
compliance with all other relevant policies, development will be supported on land within the area
identified on the policies map which provides:
3.5 As referred to above the extent of the Site boundary (red line) has been reviewed as part of the
current scheme development; in particular having regard to the landscape, ecological and access
technical work which has been completed to date. Some revisions to the Site boundary are now
proposed and these are included on the accompanying Site Plan SLP-01 P4 which is attached at
Appendix A. The extent of the Site and development boundary shown on the draft policies map we
consider should be updated to reflect the full extent of the amended site area, which is 8.828
hectares.
3.6 The amendments can be summarised as follows:
• The northern boundary: Has been adjusted to the north along Colchester Road to deliver a
better development relationship with Feedhams Close on the west side of Colchester Road
and provide a more logical settlement boundary along the northern part of the town while
allowing the slightly enlarged site to deliver an appropriate and efficient quantum of
development, reflecting the sustainability of Wivenhoe as a location. This also helps to better
accommodate the required access visibility splay to the north and provide a stronger gateway
into the settlement. Along the northern boundary from an ecological and biodiversity point of
view, it is also important to include a 5m buffer on the north side of existing hedgerow, ditch,
and tree cover, for enhancement and management purposes, however this area will not
include any built development.
• Southern boundary: This includes the track to allotments and the former care home site.
• Eastern boundary: This follows the title plan.
• Western boundary: This follows the edge of the new of allotment site.
3.7 While these changes will marginally increase the size of the site, they help to facilitate it delivering at
least the anticipated quantum of development, without compromising the ability to retain and
improve the existing important landscape trees, hedges, and ditches, and also ensure that the
biodiversity value of these features can be maximised in the long term.
a) Approximately 175 new dwellings of a mix and type of housing to meet evidenced needs and be
compatible with surrounding development;
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3.8 Criteria a) is supported, however there does need to be some flexibility in respect of the total
number of dwellings which can be delivered. Currently two different development options are being
developed, one which reflects the pylons which cross the site as being retained, and a second which
reflects Policy criterion j) showing them undergrounded. At present these options confirm that 175
dwellings are likely to be below the minimum number of dwellings the Site can deliver and in reality,
higher numbers will be achievable in order to make the most efficient use of the land available in
this sustainable location.
3.9 Both Concept Master Plan options seek to retain existing landscape features, primarily the existing
field boundaries. A single point of access is provided to Colchester Road with a main spine road
running through the Site and providing an all modes connection to the north-west corner of the
Cala Homes development.
3.10 To provide a vehicle connection between the eastern half of the Site and the west, it will be necessary
to remove a short central section of the existing hedgerow. This will be kept to a minimum and
compensatory planting will be carried out. Additional pedestrian connectivity has also been
provided to assist the integration of the Care Home land, the Cala development, the new allotments,
and the wider Site.
3.11 Generous areas of landscaping and green space have been included, with green buffers to existing
landscape features throughout. The landscaping will help to establish an appropriate rural character
to the scheme and some separation between the internal development parcels, reflective of the
Site’s edge of settlement location.
3.12 On the western side of the Site a surface water attenuation basin is proposed which can be gravity
fed from the remainder of the development area. This will also be located close to the existing
attenuation basin which serves the Cala development, and the new allotment site to the west,
creating a large natural space, rich in habitat value and adding a tranquil area to the setting of the
new allotments.
3.13 The Promoters architects are currently refining the site option plans to ensure that an efficient use
of the site can be delivered at an appropriate density to reflect the landscape sensitivity of the site,
however, the early indications are that a higher number of dwellings is likely to be deliverable and
as such it is recommended that the figure of approximately 175 dwellings is slightly increased to
approximately 200 dwellings. When the additional design work has been completed, we will provide
the Council with an update of the most realistic site capacity, to help inform the next stage of the
emerging Plan.
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b) Safe and suitable site access to required highway design standards and point of vehicle access to
be via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority and
demonstration that the proposal would not be detrimental to highway capacity or safety;
3.14 It is noted that criteria (b) of Policy PP24 seems to suggest that the; ‘…point of vehicle access to be via
the adjoining Neighbourhood Plan allocation…’ The existing access to the Cala development is
physically constrained by the existing buildings in Watsham Place and as such it is not considered
that it would be desirable in highway terms for it to serve approximately 260 dwellings.
3.15 As part of the scheme development process, it has therefore been concluded that providing a new
point of access further north along Colchester Road would deliver substantial highway safety and
amenity benefits, reducing the potential for congestion around the junctions of Vine Drive and
Elmstead Road. Additional pedestrian and cycle connections can be provided directly to Colchester
Road, as part of this new access, as well as to the new track to the allotments, in the south-east
corner of the Site frontage as well. A vehicle link to the Cala development is also proposed which
ultimately will create a loop through both sites. This will improve the over permeability of both sites.
3.16 In respect of the location of the new Site access on Colchester Road, a central location is considered
to be the only feasible option to serve the development. This is because there is not scope to locate
the access to the south due to the separation distance required from the Elmstead Road junction
and the controlled crossing, meaning there are no suitable non constrained alternative locations. A
Highway Technical Note and accompanying plans have already been provided to the Planning Policy
Team and further copies can be made available upon request. As the scheme development is
progressed engagement with Essex County Council Highways will be undertaken to help confirm
the technical acceptability of these arrangements.
3.17 It is therefore recommended that criterion b) should be amended to the following:
Safe and suitable site access to required highway design standards and point (s) of vehicle access to be
via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority and
demonstration that the proposal would not be detrimental to highway capacity or safety .
3.18 The Promoters would be happy to discuss this or another form of suitable access with the Council.
c) Provide a safe pedestrian access to ensure connectivity within and throughout the site to existing
footways and any Public Rights of Way. Ensure provision of green infrastructure connections and
recreational access to the countryside, also securing active travel links and connections to the
settlement;
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3.19 This criterion appears to be trying to address three matters, which are generally related, however,
the reference to green infrastructure connections is considered confusing as these connections are
not only associated with accessibility but also green and blue corridors where it may be more
appropriate to discourage public activity from an ecological perspective. Furthermore, there are no
public rights of way crossing, or immediately adjoining the site. It is therefore recommended that
criteria c) is amended as follows:
c) Provide a safe pedestrian and active travel access to ensure connectivity within and throughout the
site and to the settlement and surrounding area . Connections to existing footways and the track to
the allotments and where possible recreational access to the countryside should also be considered .
to existing footways and any Public Rights of Way. Ensure provision of green infrastructure
connections and recreational access to the countryside, also securing active travel links and
connections to the settlement;
3.20 The delivery of green infrastructure connections can be secured through the statutory requirements
to deliver biodiversity net gain and the general layout of the development.
3.21 If the reference to green infrastructure connections was intended to suggest that public access
should not only be provided through the urban parts of the development, but also through more
informal rural settings, then this can be explained as part of the supporting text.
d) Contributions towards enhancement of the quality and value of King George V Playing Fields;
3.22 There is no objection to this particular criterion. While the emerging scheme which is being
developed for the Site will provide the minimum 10% open space requirement currently operated
by the Council, given the size of the development it is unlikely that this will include any formal sports
facilities, and as such it is appropriate that some mitigation should be delivered providing this is not
already captured as part of the Council’s CIL charging schedule.
e) Screening comprising locally appropriate tree belts and/or hedgerows will be required along the
site boundaries to ensure that development is sensitively integrated into the landscape and to
maintain settlement separation;
3.23 This is a reasonable requirement, and the current scheme development is being informed by an
accompanying landscape strategy which seeks to retain existing hedgerows and tree belts with
appropriate buffers and introduce new tree belts and/or hedgerows where necessary along the Site
boundaries to ensure the Site is sensitively integrated into the townscape.
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f) Biodiversity enhancement measures should include enhancing hedgerow condition and
establishing grassland habitats along road verges;
3.24 There is no particular objection to this policy criteria, however, given the statutory biodiversity
enhancement requirements which will be secured through the detailed planning application stage
and a statutory biodiversity net gain condition, it is unclear why there is a site specific requirement
for establishing grassland habitats along road verges in this particular location. As such these
comments might be better included in the supporting text of policy where further explanation and
justification can be provided.
3.25 It is therefore considered that unless there is site specific justification available this criterion should
be deleted.
g) Development must conserve, and where appropriate, enhance the significance of heritage assets
(including any contribution made by their settings). Designated heritage assets close to the
allocated site includes five Grade II Listed Buildings as informed by the stage 1 HIA;
3.26 This is in line with national policy and legislative requirements which require heritage assets to be
conserved or enhanced, not conserved and enhanced. It is considered that the Site can be
developed to ensure that the setting of the nearby listed buildings are, as a minimum, preserved.
3.27 It is noted that the Heritage Impact Assessment Sift Methodology (January 2025) classified the site
as not requiring any further investigation at this stage but indicates that a proportionate heritage
impact assessment, desk-based archaeological assessment and potentially trial trenching, should
be part of the planning application stage.
h) The total number of dwellings will be spread between this site and the area currently set aside
for a care home as part of the neighbourhood plan allocation;
This criterion is supported as it will provide clarity in respect of the status of the Neighbourhood
Plan as part of the development plan and the Site’s existing designation for use as a care home.
3.28 Following the original outline permission (Ref: 213507) in January 2024 for the adjoining housing
site, which included permission for a 60 bed care home, the site was marketed and Cala Homes
purchased the residential element, however, very little interest was expressed in the Care Home
site. More recently, in October 2024, a focused marketing exercise commenced for the care home
land. Over twenty operators were contacted directly, however, despite the extensive marketing, only
one operator expressed any serious interest, and after a more detailed review concluded the site
was not suitable for their requirements.
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3.29 It is also relevant that the care home land to the rear of the Fire Station was not the only opportunity
for care home provision to be made by the Neighbourhood Plan. At paragraph 16.35, the
Neighbourhood Plan notes this and states: “Whether proposals for care homes come forward will
depend on market factors.” Furthermore, the Council have recently resolved to grant planning
permission (Ref: 240409) at the Croquet Gardens site for 25 Bungalows and a 60-Bed Care Home.
Therefore, the care home land to the rear of the Fire Station is not required or suitable for care
home use to meet any current local need and, as such, there is sufficient justification for its logical
inclusion as part of the residential allocation.
3.30 This is also recognised in the Summary of Sites Evidence (October 2025) evidence base document
as set out in Section 4 below.
i) A new community space must be included within the site and pedestrian access to the adjacent
allotments must be created;
3.31 The Site Promoters would be agreeable to including a community space/land as part of the scheme
development, however, there needs to be a clear vision around what is actually necessary,
proportionate, and justified.
3.32 At the present time, this criterion is considered to be imprecise in respect of the size and type of
community space which is required and is lacking justification.
3.33 While pedestrian access will clearly be provided to the adjacent allotments through the inclusion of
the allotment access track, this can also be secured under criterion c) above.
3.34 Having regard to the limited information in the Infrastructure Audit and Delivery Plan (October 2025)
(IADP), which it is acknowledged does refer to a limited range of community facilities at Table 3.25
(Page 69). However, it does not expand this any further and explain which community facilities there
are a shortage of. It is noted that those facilities listed in the introduction to section seem to relate
to buildings such as community halls and libraries rather than ‘spaces’.
3.35 While the Sustainability Appraisal refers to this as a potential community benefit for residents in the
north of the settlement, it fails to provide any further guidance what is expected.
3.36 The reference in the IADP does not seem to align with the assessment set out in the Settlement
Evidence Stage 1 Document (November 2024). This evidence document includes an analysis of
Wivenhoe (Page 108 onwards) which generally confirms that it is a sustainable location with a good
range of community facilities and local services. This does not suggest a shortage of community
buildings. At Page 109 it states:
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“There is numerous community and social infrastructure in Wivenhoe. There is a GP
surgery, dentist surgeries, shops including a One Stop, Co -op and numerous
independent shops. There is a library , three hair salons and three barbers, art galleries.
There are nine public houses/restaurants, four cafes, a fish and chip shop, football
ground, tennis courts, cricket ground, bowls club, allotments and open space provision
including playing fields. Ther e are multiple churches and community halls .” [emphasis
added]
3.37 Under the section on High Level Opportunities (at a settlement level), whilst it suggests that growth
may provide opportunities to enhance local infrastructure, including active travel within the
settlement and beyond, there is no mention of a need for additional community spaces or buildings.
There is, however, reference to the Wivenhoe Green Spaces Community Project which
demonstrates how a mosaic of sites of varying sizes contribute to the green infrastructure of the
town and encourage diversity of wild flowers on green spaces, bringing significant ecological, climate,
and heritage benefits.
3.38 As referred to above, noting that the Council is a CIL charging authority and 25% of CIL receipts will
be transferred directly to Wivenhoe Parish Council to spend on local projects, there does not appear
to be any reasonable justification for this criterion at present.
3.39 Furthermore, criterion d) indicates there is a particular need for contributions towards the
enhancement of the quality and value of King George V Playing Fields which it is assumed would be
secured separately to CIL, through a Section 106 Agreement. Requiring the Site to deliver a further
additional community space or land as well as a contribution to this existing community recreation
space is not considered reasonable or proportionate to the scale of the proposed development. As
such it is not likely to be compliant with the tests set out in the CIL Regulations without further
appropriate site-specific justification.
3.40 In respect of the current scheme development work, without more precise understanding of what
a community space may be required to deliver it is difficult to understand where it might be best
located on the site, the type and extent of land required, the potential neighbouring impact it may
have and what accessibility requirements may be necessary. It would therefore be extremely helpful
to have further clarification on this matter if the criterion is to be retained.
3.41 In summary, at the present time it is therefore considered that criterion i) should be deleted or
further site specific justification should be provided.
j) Opportunities for undergrounding should be explored
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3.42 There is no objection to this criterion. At the beginning of July 2025 notice was served by the
landowner on Eastern Power Networks Plc that their Wayleave Agreement which crosses the Site,
will be terminated on 15th January 2026. This is the first step towards potentially securing the
ungrounding of the existing overhead power lines. However, at this stage it is not known whether
this is a realistically viable option. As such, as referred to above, two layout options, with and without
undergrounding, have been prepared and are being developed further.
3.43 It should also be noted that there is a mains sewer which follows the alignment of the existing Pylons
which means the two different schemes do not vary dramatically with a linear open space running
through the Site, even if the existing overhead power lines were to be undergrounded. This is not
to say there would not be visual and environmental benefits from fully exploring the opportunity for
undergrounding.
k) Development must discharge attenuated surface water to a receiving waterbody and not to the
combined sewer network, unless it can be demonstrated that there is no other option.
3.44 There is no objection to this criterion. A drainage strategy is being prepared as part of the scheme
development and, as referred to above, a technical note, Flood Risk and Drainage has already been
provided to the Council which confirms that surface water can be discharged to an appropriately
sized attenuation basin on site. A further copy of this technical note can be provided if required.
l) Demonstrate adequate capacity for managing wastewater including proposed phasing
requirements or alternative solutions to the satisfaction of the Council and Anglian Water;
3.45 As referred to above, a drainage strategy to inform the scheme development is being developed
and this will include engagement with Anglian Water.
3.46 Although as a statutory consultee, consultation would undoubtedly take place in connection with
this and other criteria, it is the local planning authority (not Anglian Water or any other body) that
makes the final decision on planning applications, accordingly it is inappropriate for Anglian to be
included in the Policy. References to the need for consultation and capacity issues if they exist can
be included in the support text.
3.47 It is relevant to note that Anglian Water have been raising issues up and down the country, objecting
to development due to insufficient capacity, and these objections are being further tested through
the courts. However, the law is clear that Anglian Water has a duty under the Water Industry Act
1991, to accept connections to the public sewer which they accept; the current issue is where there
is a shortage of headroom in the receiving waste water recycling centre (WRC), the speed at which
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appropriate capacity can be delivered. Clearly, through a plan led system, there should not be a
problem for the sewage undertaker to align its asset management upgrade programme, a five year
cycle, with the housing trajectory proposed through a Local Plan and early engagement by site
promoters as well as the local planning authority will assist with this. This is clearly a matter which
should also be addressed through the infrastructure delivery plan and in turn needs to be linked to
the Council’s housing trajectory.
3.48 In conclusion the reference to Anglian Water in criterion l) should be deleted.
m) A range of measures in addition to prioritising SuDs (Policy EN8) and water efficiency measures
to reduce the risk on impact on the WRC capacity as a result of planned growth including:
i. Removal of unrequired network flows;
ii. Targeted education to include new residents of the development;
iii. Reduction in the demand for potable water.
3.49 It is unclear why this particular criterion has been included given the requirements for a site specific
flood risk assessment and drainage strategy, which would need to be in accordance with Policy EN8
and cover the items listed as i) to iii) above. In addition, as referred to in the comments above in
respect of criterion l) consultation with Anglian Water will be required and the above issues will be
addressed through this mechanism. It will also be linked to the infrastructure delivery plan and
housing trajectory.
3.50 It is considered that it would be more appropriate for this matter to be referred to in the supporting
text rather than as an additional policy element.
3.51 Criterion m) should be deleted.
n) Any site specific infrastructure requirements from the IDP (likely to include education provision,
highway mitigation, water and wastewater and specific community / open space provision).
3.52 There is no objection to this particular criterion, however, any site specific infrastructure
requirements will need to meet the statutory requirements as set out in Regulation 122 of the CIL
Regulations 2010 (as amended) i.e. be:
(a) necessary to make the development acceptable in planning terms;
(b) directly related to the development; and
(c) fairly and reasonably related in scale and kind to the development .
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3.53 This will be particularly important bearing in mind that the Council is already a CIL charging authority
and there should be no double counting when considering infrastructure and mitigation.
3.54 In the national policy context of producing succinct local plans, as a general good practice comment
including this requirement does seem to be an unnecessary “belt and braces” approach, given the
reference to Policy ST7 in the introduction to the Policy, as well as the requirements set out in the
other criteria discussed above.
3.55 In conclusion it is recommended that criterion n) is deleted.
o) Before granting planning consent, wintering bird surveys will be undertaken at the appropriate
time of year to identify any offsite functional habitat. In the unlikely event that significant numbers
are identified, development must firstly avoid impacts. Where this is not possible, development
must be phased to deliver habitat creation and management either on or off-site to mitigate any
significant impacts. Any such habitat must be provided and fully functional before any
development takes place which would affect significant numbers of SPA birds
3.56 There is no objection to this criterion given the environmental sensitivities of the surrounding
protected sites. As part of the scheme development, ecologically assessments have been carried
out including bird surveys which were undertaken during January, February, and March 2025. These
confirmed that any use of the site by waterfowl was negligible. These results are included in the
Preliminary Ecological Appraisal which has already been provided to the Council. This assessment is
further supported by the surveys previously undertaken in relation to the CALA and Care Home site
which are also still relatively recent, albeit now out of date, but again not identifying any particular
concerns.
3.57 These conclusions are also supported by the Emerging Allocations Biodiversity Assessment as
referred to in Section 5 below.
All development Proposals within Wivenhoe Neighbourhood Plan Area, will also be determined
against the policies in the Wivenhoe Neighbourhood Plan (Adopted May 2019) where they are up
to date and relevant.
3.58 There is no objection to the final paragraph of the Policy which acknowledges the existence of the
Wivenhoe Neighbourhood Plan, which will remain part of the development plan for the area. This
helpfully confirms that the weight attached to its policies for decision making purposes in the future
will need to be moderated having regard to its age, consistency with the Local Plan strategic policies,
and national planning policy at the time of the determination of any future planning application
Colchester Local Plan Reg 18 | Wivenhoe Policy PP24
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PP24 Summary
3.59 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
inclusion of Policy PP24 in the Plan. While the above section includes some relatively detailed
commentary in respect of the particular criteria and wording of Policy PP24, these are not intended
to be a criticism, but a positive review to assist the Council with the drafting of the forthcoming
version of the Policy and supporting text to be included in the Regulation19 submission version of
the Plan, to help ensure that the Plan can be found sound on examination with limited modification.
3.60 A track change version of Policy PP24 has been provided at Appendix B capturing the recommended
amendments set out above. In conclusion this representation supports Policy PP24 subject to the
recommended refinements and minor amendment to the Site area as indicated at Appendix A,
ensuring flexibility, clarity, and deliverability of the Site in the early part of the Plan period.
Colchester Local Plan Reg 18 | Wivenhoe Policy PP24
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4. POLICY GN5, SUSTAINABILITY APPRAISAL AND EVIDENCE BASE
Policy GN5: Suitable Alternative Natural Greenspace
4.1 It is noted that the emerging Plan, includes Policy GN5: Suitable Alternative Natural Greenspace. This
policy requires that the Natural England standard of 8 hectares per 1000 head of population be
applied where it is necessary to provide alternative greenspace as the result of a Habitat Regulations
Assessment. It is proposed that the policy wording should be reviewed to allow flexibility in the
application of this ratio, as opposed to an arbitrary calculation, and consideration should be given to
only applying it strategic scale development for example, over 1,000 dwellings.
4.2 On the basis that we would anticipate that an HRA for this particular site (Policy PP24) would be likely
to identify an impact on locally sensitive sites, we would suggest that a further consideration should
be given as to how the Council anticipate this standard might be delivered, noting that the direct
application of this standard to the Site would require an additional area of 3.36 ha of Greenspace to
be provided.
4.3 Such a requirement in addition to the existing land take to meet open space standards, on site SUDs
and on site BNG, would result in a significant reduction in the current housing potential, making the
current policy proposal for 175 dwellings unrealistic. This standard may also have a serious impact
on the viability on this Site and other similar proposed allocations
4.4 Furthermore, sites in Colchester do of course make RAMs contributions to seek to manage
recreational disturbance pressures, so again, this is a factor that should be taken into account
alongside the Natural England ratio which may not consider local factors such as this and effectively
result in double counting in conflict with the CIL Regulations.
Sustainability Appraisal Report (February 2025)
4.5 Both the Site and the wider allocation (PP24) have been considered within the evidence base
documents to the emerging Local Plan, including the Sustainability Appraisal Report (February 2025)
(the SA) which assesses whether the emerging Local Plan will help achieve sustainable development
when compared with reasonable alternatives.
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4.6 The SA confirms that Wivenhoe is a sustainable settlement and has good infrastructure provision
and is one of the four largest towns beyond the City of Colchester. However, it also indicates that the
proportion of growth directed to Wivenhoe and West Mersea is lower than the other two larger
settlements of Marks Tey and Tiptree owing to the internationally important biodiversity
designations.
4.7 At Table 5.36, a summary of the SA findings in respect of Policy PP24 is provided and expanded upon
at Paragraphs 5.323 to 5.329. It is considered that this provides a fair assessment of the Policy based
on the existing evidence base. It is noted that the conclusion is that no recommendations are
proposed for any changes to the Policy. In respect of the assessment, some of the areas where
negligible effects have been recorded, for example in respect of the historic environment (SA
Objective 7), Biodiversity and Geodiversity (SA Objective 8) and Landscape (SA Objective 9) a higher
score may well be achieved following the completion of the Site specific technical assessments
currently being undertaken by the Promoters, which will provide further detail and clarification on
the potential positive mitigation which can be delivered.
4.8 In conclusion, it is considered that the SA provides a robust assessment of the proposed allocations
and polices in the emerging plan. It has considered a comprehensive range of reasonable
alternatives, identified suitable and relevant options, and as such, is supported.
Summary of Sites Evidence (October 2025)
4.9 As part of the evidence base for the emerging Local Plan, the Council have produced a Summary of
Sites Evidence (October 2025) which contains a summary of the sites assessed as part of developing
the new Local Plan for housing and employment. These sites were collated via a ‘Call for sites’
exercise or a desktop review, with sites then assessed using the Strategic Land Availability
Assessment (SLAA). The Summary report also confirms that in bringing forward site allocation
choices within the Preferred Options Local Plan, other evidence base documents were used to
inform the suitability of sites.
4.10 The Site is considered under the name ‘Land North of the Fire Station’ Wivenhoe (Site Ref: 10755)
along with the other site submissions for the settlement. As part of the assessment the submitted
Site has been extended to include the ‘Care Home Land’ to the south. This amendment is supported
by the Promoters, however as referred to above a further modest increase in the site area as
discussed above and identified on the red line plan at Appendix A would also be beneficial.
Colchester Local Plan Reg 18 | Wivenhoe Policy PP24
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4.11 While the assessment acknowledges that the proposed allocation encroaches into the coalescence
area designated in the Wivenhoe Neighbourhood Plan, it helpfully acknowledges that the
encroachment is less than other proposals. It would be useful if the assessment were to highlight
that the allocation does not extend any further north along Colchester Road into the coalescence
break area than the northern boundary of the existing settlement around Feedhams Close on the
west side of Colchester Road when this report is updated next. It will also be necessary for it to reflect
the revised red line plan included at Appendix A.
4.12 The assessment also helpfully acknowledges that:
“The site is adjacent to one of the neighbourhood plan allocations and development can
be planned to complement that development, including delivering some of the homes
allocated on part of the existing allocation set aside for a care home, which is no lon ger
needed owing to the proposal for a care home on an alternative site in Wivenhoe. Access
can be made to the allotments to be delivered as part of the existing allocation
(currently with outline consent).”
4.13 This clarification is supported and considered helpful.
Emerging Allocations Biodiversity Assessment
4.14 The emerging allocations biodiversity assessment has undertaken a review of the proposed
allocation which is set out on page 60 of the report. The harm scoring is noted as:
“Little/no harm – the site has limited natural habitat value”
4.15 This assessment is supported and the general commentary is considered to be a fair reflection of
the Sites biodiversity value and potential, having regard to the site-specific ecological, arboricultural,
and landscape technical work which has recently been completed by the Site Promoters.
Heritage Impact Assessment Sift (January 2025)
4.16 The Heritage Impact Assessment Sift Methodology (January 2025) was a desk-based assessment of
each site to identify any heritage assets with the potential to be affected by their allocation. Following
the sift, three levels of further heritage impact assessment are recommended depending on the
potential impact of the allocation of a site on the historic environment. These were categorised as:
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• No further assessment: (the allocation of the site has been assessed to have no effect on the
significance of any heritage assets);
• Proforma Heritage Impact Assessment; and
• Detailed Heritage Impact Assessment.
4.17 The Land North of the Fire Station was assessed to fall within the first category, no further
assessment required and this conclusion is supported given the limited proximity of the nearest
designated heritage assets.
4.18 It is acknowledged that the site assessment indicates that a heritage statement will be required to
inform the layout of the site and scale of development, given the listed buildings in Colchester Road.
It is also noted that the assessment indicates that a desk-based archaeological assessment will be
required, potentially supported by trial trenching.
Colchester Infrastructure Audit and Delivery Plan, October 2025 (IADP)
4.19 The IADP at Table 2-3 indicates the planned housing growth over the plan period, for Wivenhoe
years 1-5 there are 175 houses planned. The opportunity for the Site to come forward early in the
plan period is supported and its ability to contribute fully to the Council’s ability to demonstrate a
five year housing land supply at the point of adoption is welcomed. As referred to elsewhere in this
consultation response, the Promoters are actively working towards the submission of an outline
application later this year (2026) to ensure that this delivery timetable is not delayed.
4.20 The above further demonstrates the suitability, availability, and deliverability of the Site for
residential development.
4.21 Appendix A of the IADP at Project ID 159 Transport, under Active Travel identifies the Wivenhoe
Mobility Hub as Phase 2, delivery 2029-2033, at an unfunded cost of £506,880 and continues under
the Funding Sources
Funding not secured. Developer funding expected from S106 and/or S278. Potential grant funding
routes include BSIP and LuF Proposed Funding Split - 100% contribution from preferred
allocations - 0% contribution from reference case developments - 0% contribut ion from external
grants.
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4.22 Clearly this a project which will not only benefit the future occupants of the Policy PP24 allocation,
but also the existing residents of Wivenhoe and the wider area. From the table it is unclear which
allocations are expected to contribute to this particular infrastructure upgrade. Having regard to the
CIL Tests what the reasonable and propionate financial contribution would be expected from the
development allocations, it is assumed that the reference to ‘0% contribution from reference case
developments ’ means this will be pooled contribution and a modest contribution is that would be
expected as a from development of the Site (Policy PP24).

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5. CONCLUSION
5.1 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
inclusion of Policy PP24 in the Plan. They welcome the opportunity to work with Planning Officers to
further refine the Policy and ensure that the Site is both a developable and deliverable housing
opportunity and can be delivered in in the early part of the plan period, helping the Council
demonstrate a five year housing land supply upon adoption.
5.2 Wivenhoe is a sustainable settlement and is one of the four largest towns beyond the City of
Colchester and an appropriate location to direct development in accordance with the Council’s
proposed development strategy which is supported along with the robust approach adopted by the
Sustainability Appraisal.
5.3 The draft Plan confirms that Wivenhoe benefits from a good range of infrastructure, including a
mainline train station, GP surgery, two primary schools, numerous shops and restaurants, and
abundant open space provision. It also benefits from public transport connections to Colchester
and a good cycle and footpath network which provide good connections to the University of Essex
amongst other destinations. As such, the Town can be acknowledged as a sustainable location, in
line with the Plans development strategy for the accommodation of further growth. This is
welcomed.
5.4 It is the Promoter’s intention to work up a formal pre-application submission to help further develop
the details of the Site proposals ahead of the potential submission of an outline application later in
the year, which will help to confirm that the Site is developable and provide a clearer indication of
when housing delivery will be likely to commence.
5.5 The Promoters consider that this represents an exciting opportunity for them to deliver a high
quality housing scheme which responds to the established environmental character of the
settlement edge and provides a range of modern homes in a beautiful, green, and sustainable
location, to meet the needs of the growing local community. Delivering a development which will
foster a strong sense of community and promote healthy and sustainable life styles, with a lasting
legacy and sense of pride, is a key objective.
Colchester Local Plan Reg 18 | Wivenhoe Policy PP24
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5.6 While this represent includes some relatively detailed commentary in respect of the particular
criteria and wording of Policy PP24, these are not intended to be a criticism, but a positive review to
assist the Council with the drafting of the forthcoming version of the Policy and supporting text to
be included in the Regulation19 submission version of the Plan, to help ensure that the Plan can be
found sound on examination with limited modification.
5.7 In summary, the Promoters support the Plan and Sustainability Appraisal along with the Council’s
assessment that the Site is suitable, available, and achievable within the plan period. Its early delivery
will also strengthen the Plan’s housing trajectory and the future five year housing land supply. This
representation supports Policy PP24 subject to the recommended refinements to the wording
recommended in Section 3 above and captured in track changes version of the Policy included at
Appendix B, as well minor amendment to the Site area (increased to 8.828 hectares) as indicated in
the Plan at Appendix A.
5.8 Inclusion of these amendments will help to ensure flexibility, clarity, and this representation aims to
confirm the deliverability of the Site in the early part of the Plan period.
Colchester Local Plan Reg 18 | Wivenhoe Policy PP24
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Appendix A - Revised Site Plan (Red Line) – SLP-01 P4
Proposed Amended Site Area


Revised Site Area Approximately 8.828 hectares

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Appendix B – Recommended Amendments to Policy
PP24
Policy PP24: Land Northwest of the Fire Station, Wivenhoe
In addition to the infrastructure and mitigation requirements identified in Policy ST 7 and subject to
compliance with all other relevant policies, development will be supported on land within the area
identified on the policies map which provides:
a. Approximately 200 new dwellings of a mix and type of housing to meet evidenced needs and be
compatible with surrounding development;
b. Safe and suitable site access to required highway design standards and point(s) of vehicle access
to be via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority
and demonstration that the proposal would not be detrimental to highway capacity or safety;
c. Provide a safe pedestrian and active travel access to ensure connectivity within and throughout
the site and to the settlement and surrounding area. Connections to existing footways and the
track to the allotments and where possible recreational access to the countryside should also be
considered. to existing footways and any Public Rights of Way. Ensure provision of green
infrastructure connections and recreational access to the countryside, also securing active travel
links and connections to the settlement;
d. Contributions towards enhancement of the quality and value of King George V Playing Fields;
e. Screening comprising locally appropriate tree belts and/or hedgerows will be required along the
site boundaries to ensure that development is sensitively integrated into the landscape and to
maintain settlement separation;
f. Biodiversity enhancement measures should include enhancing hedgerow condition and
establishing grassland habitats along road verges;
g. Development must conserve, and where appropriate, enhance the significance of heritage assets
(including any contribution made by their settings). Designated heritage assets close to the
allocated site includes five Grade II Listed Buildings as informed by the stage 1 HIA;
h. The total number of dwellings will be spread between this site and the area currently set aside
for a care home as part of the neighbourhood plan allocation;
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i. A new community space must be included within the site and pedestrian access to the adjacent
allotments must be created;
j. Opportunities for undergrounding should be explored;
k. Development must discharge attenuated surface water to a receiving waterbody and not to the
combined sewer network, unless it can be demonstrated that there is no other option.
l. Demonstrate adequate capacity for managing wastewater including proposed phasing
requirements or alternative solutions to the satisfaction of the Council and Anglian Water;
m. A range of measures in addition to prioritising SuDs (Policy EN8) and water efficiency measures
to reduce the risk on impact on the WRC capacity as a result of planned growth including:
i. Removal of unrequired network flows;
ii. Targeted education to include new residents of the development;
iii. Reduction in the demand for potable water.
n. Any site specific infrastructure requirements from the IDP (likely to include education provision,
highway mitigation, water and wastewater and specific community / open space provision).
o. Before granting planning consent, wintering bird surveys will be undertaken at the appropriate
time of year to identify any offsite functional habitat. In the unlikely event that significant numbers
are identified, development must firstly avoid impacts. Where this is not possible, development
must be phased to deliver habitat creation and management either on or off-site to mitigate any
significant impacts. Any such habitat must be provided and fully functional before any
development takes place which would affect significant numbers of SPA birds.
All development Proposals within Wivenhoe Neighbourhood Plan Area, will also be determined against
the policies in the Wivenhoe Neighbourhood Plan (Adopted May 2019) where they are up to date and
relevant.

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.

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 Brook Meadows, Tiptree (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 Site is identified within the Council's assessed site pool as SLM ID 10132.
3. The Council is currently progressing the Site as a Biodiversity Net Gain ("BNG") allocation, and we support the principle of Brook Meadows performing a strategic biodiversity and green infrastructure role. The Council's supporting evidence explicitly identifies Brook Meadows, Tiptree as a preferred off-site BNG location within the Plan's approach to BNG delivery.
4. However, the Site should not be treated as a single-purpose allocation by default. For plan-making purposes, the Preferred Options Plan should also test, transparently, whether the Site should be allocated for landscape-led residential development, either in whole or in part, including a hybrid approach where a residential component is brought forward alongside a strategically significant BNG and green infrastructure function. This is advanced on an "in principle" basis and is not intended to commit to a fixed quantum, detailed design or delivery programme at this stage.
5. We welcome the opportunity to comment on the emerging Local Plan. Our representations relate specifically to Land at Brook Meadows, Tiptree, and are provided to assist the Council in refining the Preferred Options approach for this location. For clarity, references to "the Site" in these representations refer to Land at Brook Meadows, Tiptree.

6. A proportionate suite of technical work has been undertaken historically and has been supplemented more recently to inform the Site's promotion and to provide context on baseline conditions and potential mitigation pathways. While time has passed and any future scheme would be supported by updated evidence as appropriate, the available material indicates that relevant matters such as access and movement, landscape and green infrastructure structuring, ecology and biodiversity enhancement, drainage and flood risk, amenity and heritage considerations can be addressed through a comprehensive, landscape-led approach and appropriate mitigation.
7. A site location plan is included below for ease of reference.


8. 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 approach to site selection and the transparent testing of reasonable alternatives for the Site, including BNG-only, residential and hybrid options;
the overall housing requirement, delivery assumptions and the need for a resilient supply position across the plan period, including a realistic contingency margin;
the spatial strategy and the application of countryside policies to edge-of settlement opportunities at Tiptree; and
the environmental and green network policy framework and how it should be translated into criteria-based allocation requirements that secure delivery and long-term management.


Plan Making Context

9. 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.
10. 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).
11. 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).

12. 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. It also highlights that larger sites should demonstrate planned investment in infrastructure and scope for environmental gains, including biodiversity net gain; 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).
13. A fundamental principle of the Framework is therefore the delivery of sustainable development through a plan-led system, achieved 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

14. 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.
15. 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.
16. The Government has also brought forward the Planning and Infrastructure Act 2025, 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.
17. A further central component of the reforms is the move to a faster plan-making process. Government proposals for the reformed system set out the expectation that local planning authorities should prepare a single local plan and adopt it within an accelerated timetable, with the objective of reducing 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.
18. 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 alongside an initial Government response, signalling a continued focus on delivery at scale through a range of new town typologies. While that specific growth agenda 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.
19. 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.

20. The reforms also sit alongside a clear national expectation that development should secure environmental gains in practice, including the delivery of measurable biodiversity outcomes. In plan-making terms, this heightens the importance of ensuring that the Plan's approach to biodiversity net gain is not treated as separate from housing delivery but is integrated into the allocation strategy through realistic delivery mechanisms, clear long-term management expectations, and site choices that can secure multiple objectives in a coordinated way.
21. 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.
22. 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, site availability and suitability, infrastructure capacity and delivery planning, 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.
23. 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.

24. 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 Brook Meadows, Tiptree can contribute to the Plan's delivery objectives through a plan-led approach that secures meaningful biodiversity outcomes and, crucially, ensures the Site is not treated as a single-purpose allocation by default. The Preferred Options Plan should therefore transparently test reasonable alternatives for the Site, including a BNG-only approach, a landscape-led residential approach, and a hybrid approach in which a residential component is brought forward alongside a strategically significant biodiversity and green infrastructure function, shaped through masterplanning and appropriate mitigation to respond to countryside and sustainability considerations.



Site Context
Land at Brook Meadows, Tiptree (SLAA ID 10132)

25. The Site is located at Land at Brook Meadows, Tiptree within the administrative area of Colchester City Council and is promoted through the Council's Call for Sites and Strategic Land Availability Assessment process (SLAA Site ID 10132). The SLAA Stage 2 assessment records the Site area as approximately 11.65 hectares and identifies the proposed uses as Housing and Green Infrastructure.
26. In locational terms, the Site lies on the western edge of Tiptree, adjoining the built-up area and extending along the settlement edge. It is influenced by residential development along Maldon Road (B1022) and the adjoining streets, including Brook Meadows and Pennsylvania Lane.
27. The Site relates directly to the B1022, which provides the primary north to south route through Tiptree and forms a key connection to the wider network. In addition, the Site sits adjacent to a landscape that has been shaped by historic sand and gravel extraction to the west, now comprising restored land including waterbodies and woodland, which forms an established green and blue infrastructure context.
28. The Site is recorded as being wholly within Flood Zone 1 and not within a Critical Drainage Area. The SLAA also identifies no reasonable highway constraints in principle, noting that access is considered safe and suitable, and records that the Site is adjacent to or within close proximity of the existing settlement boundary and would not lead to coalescence.

29. A defining characteristic of the Site is its relationship with locally designated ecological assets. The appeal decision records that the Site, together with the adjacent restored gravel pits to the west, forms part of the lnworth Grange and Brook Meadows Local Wildlife Site. The SLAA likewise records that more than 50% of the Site lies within a local designation of this type.
30. The Site's movement context includes public rights of way in the immediate vicinity. The appeal decision records that public footpaths run outside parts of the southern and north western boundaries, and that a short length of Footpath 19 lies within the Site close to its western boundary, with further routes in the surrounding network. This provides a clear basis for considering how any future allocation could secure enhanced access and connectivity, and how green infrastructure and biodiversity objectives could be delivered alongside, and not in isolation from, wider plan objectives.
31. The Site has also been the subject of previous development promotion and decision making, including an outline planning application for residential development which was refused and subsequently dismissed on appeal (Appeal Ref APP/A1530/W/22/3301862, decision dated 05 December 2022). This historic context is not rehearsed in detail in these representations. Its relevance for the current plan-making exercise is that the Preferred Options Plan now provides the appropriate mechanism to determine, transparently, the most suitable planning role for the Site through the testing of reasonable alternatives and, where appropriate, the setting of clear, criteria-based allocation requirements.
32. In terms of form and content, and without committing to a fixed quantum or a detailed scheme at this stage, the Site is capable, in principle, of supporting a landscape-led approach that secures meaningful ecological outcomes through the long-term management and enhancement of the Local Wildlife Site resource and its connections to the adjoining restored land. If the Plan considers that a residential or hybrid role is appropriate, that could theoretically be structured so that built development, open space, access and biodiversity delivery are planned comprehensively, with retained landscape structure and buffered ecological assets forming the organising framework for any future proposals.
33. The Site is therefore well placed to be considered through the Preferred Options process as part of a resilient plan strategy, particularly where the Council is seeking to ensure that allocations are deliverable, flexible and capable of maintaining an effective supply position over the plan period, while also securing measurable biodiversity outcomes. The following sections build on this site description by addressing the relevant strategic

and development management policies and by setting out the case for the Plan to transparently test reasonable alternatives for the Site, including BNG-only, residential and hybrid options.


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

34. 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.
35. 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.
36. 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, or that reasonable alternatives are not transparently tested.


Policy ST3: Spatial Strategy

37. 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.
38. 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 site selection. This is important for two related reasons.
39. 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 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 remain capable of accommodating strategic allocations where they strengthen plan effectiveness and delivery resilience.
40. 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 wider community and environmental benefits. The spatial strategy should therefore be applied in a way that allows the Council to test and, where justified, select sites that are capable of delivering multiple objectives, rather than defaulting to single-purpose categorisation at Preferred Options stage.
41. In practical terms, that means the Council should ensure that Land at Brook Meadows, Tiptree 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 SLAA Site ID 10132, with promoted uses recorded as housing and green infrastructure.
42. That approach is particularly important here because the Site is currently being progressed as a BNG location, and there is a material plan-making question as to whether a BNG-only approach is the most justified and effective option when compared against residential and hybrid alternatives. The Council's evidence identifies Brook Meadows as a preferred off-site BNG location, which supports the principle of an environmental role. However, ST3 requires the Council to balance objectives, and the Plan must therefore test whether a hybrid approach could secure strategic biodiversity outcomes while also contributing to housing delivery in a landscape-led manner, thereby improving overall plan effectiveness and resilience.

Policy ST4: Development in the Countryside

43. 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.
44. 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.
45. The key issue is how ST4 is applied in plan-making terms at the edge of a Large Settlement. Even where land lies outside the defined settlement boundary and is therefore treated as countryside, ST4 is expressly drafted to allow countryside development where required to meet identified needs in accordance with the spatial strategy. 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 the testing of edge-of-settlement opportunities where the evidence indicates they may contribute to a deliverable plan strategy.
46. This is directly relevant to Brook Meadows. The Site is on the edge of Tiptree, adjoining the built-up area, and sits within a sensitive environmental context, including its relationship with a Local Wildlife Site designation and the adjoining restored land to the west. We recognise and accept that baseline. It means that any consideration of residential or hybrid options must be advanced on a landscape-led and mitigation-led basis and should not be justified by downplaying ecological sensitivities.
47. However, that baseline does not remove the plan-making question that ST4 itself raises, which is whether there are countryside edge locations that can meet identified needs through comprehensive planning and mitigation, including by securing long-term habitat management, enhanced public access where appropriate, and green and blue infrastructure delivery as the structuring framework for the site. The appeal history provides relevant context that the Site has previously been tested in decision-making terms, but the Preferred Options Plan is now the correct mechanism to determine the Site's role through transparent reasonable alternatives testing and, if progressed, through clear criteria-based requirements that secure avoidance, mitigation and long term stewardship.

48. Taken together, the application of ST3 and ST4 should therefore lead the Council to test Brook Meadows transparently through the evidence base and Sustainability Appraisal as:
a. a BNG-only option, including the deliverability and long-term management implications of that approach;
b. a landscape-led residential option, structured to avoid and mitigate effects on sensitive assets; and
c. a hybrid option, where biodiversity delivery and green network functions are secured as the organising framework and any residential component is planned and controlled through clear criteria and long-term management arrangements.
49. Where that assessment demonstrates that impacts can be appropriately managed and that delivery can be secured in a comprehensive way, the Plan should not preclude a residential or hybrid allocation outcome solely because the land falls outside the current settlement boundary. A criteria-led approach under ST4 would strengthen the Plan's resilience, provide flexibility in the supply portfolio, and ensure that biodiversity objectives are secured through clear mechanisms, consistent with the effectiveness test in NPPF paragraph 36 and the requirement in NPPF paragraph 72 to identify sites having regard to deliverability, suitability and likely viability.



Housing Needs and Delivery
Draft Policy ST5, Local Housing Need, five-year housing land supply and the role of the Garden Community (Draft Policy ST9) within delivery risk management
50. Draft Policy ST5 sits at the core of the Preferred Options Plan because it translates the Council's housing evidence into a quantified requirement and, critically, into a delivery strategy capable of implementation. This approach aligns with the National Planning Policy Framework (December 2024), which requires strategic policies to meet identified needs (NPPF paragraph 11) and to identify and maintain a sufficient supply and mix of sites (NPPF paragraphs 72 and 78).
51. The Council's evidence identifies a local housing need figure of 1,300 dwellings per annum, which the Preferred Options Plan treats as the mandatory target for plan-making purposes. This is an important anchor for ST5, particularly in the context of the Government's stated objective of materially boosting housing delivery and the wider reform direction towards clearer requirements, streamlined plan-making and a stronger focus on implementation and build-out.

52. The supporting Habitats Regulations Assessment at Preferred Options stage also confirms the scale of the Plan's approach, identifying a requirement of 20,800 dwellings between 2025 and 2041 (1,300 dwellings per annum) and setting out the principal components of supply, including commitments, a windfall allowance, proposed Local Plan allocations and an assumed contribution from the Tendring Colchester Borders Garden Community.
53. In principle, we support the Council's intention to plan positively by identifying a portfolio which, on paper, is capable of meeting the requirement. However, the key issue for ST5 is not whether the Plan can show a headline supply position, but whether the supply is supported by delivery assumptions that are realistic, transparent and resilient to foreseeable delivery risks. This reflects the NPPF's emphasis that delivery rates must be realistic for large-scale development (NPPF paragraph 77) and that authorities should maintain supply through an annually updated stock of deliverable sites, with the appropriate buffer (NPPF paragraph 78).
54. For delivery context, the most recent published Housing Delivery Test measurement (2023) indicates that Colchester delivered 110% of its requirement over the relevant measurement period and is not subject to the policy consequences that apply where delivery falls below the specified thresholds (NPPF paragraph 79). This is a helpful monitoring position. It does not, however, remove the plan-making requirement to ensure ST5 is underpinned by a delivery strategy that is robust over a long plan period to 2041.
55. Delivery risk over a plan period of this length is unavoidable due to market cycles, infrastructure dependencies, lead-in times, labour and materials constraints, and the practical realities of phased build-out. The Government's reform agenda, including its emphasis on delivery and build-out transparency, heightens the importance of realism at plan stage. A plan that depends on a narrow range of supply sources or optimistic delivery trajectories is more exposed to slippage than a plan supported by a balanced and diverse portfolio of sites.
56. In that context, ST5 should be applied alongside a realistic contingency margin and a balanced portfolio of allocations. This aligns with the function of the NPPF buffer, which is intended to ensure choice and competition and improve the prospect of achieving planned supply (NPPF paragraph 78). The practical corollary is that any apparent plan wide "surplus" should be treated as a necessary allowance for slippage, rather than a reason to exclude otherwise suitable and deliverable allocation options.

57. The Council's five-year housing land supply evidence is relevant as a lens on deliverability assumptions and transparency. The Council's most recent Housing Land Supply Position Statement (base date 1 April 2025) confirms that, for five-year supply purposes, Colchester has historically monitored delivery against the adopted Local Plan annual requirement of 920 dwellings per annum, applying a 5% buffer, and reports a marginal five-year position on that basis.
58. While five-year supply monitoring is a distinct exercise, it is directly relevant to ST5 in two ways. First, the Preferred Options Plan is proposing a materially higher annual requirement (1,300 dwellings per annum). The Plan's delivery framework and trajectory therefore need to be calibrated to the higher delivery challenge, rather than relying on assumptions that are rooted in the historic adopted requirement. Second, the Plan's trajectory should be internally consistent with the Council's approach to lead-in times, build rates and deliverability evidence used for monitoring, so that ST5 is demonstrably effective and not reliant on optimistic or untested assumptions.
59. Similarly, where the Council relies on windfall within the overall supply position, the NPPF requires compelling evidence that windfalls will provide a reliable source of supply, and that the allowance is realistic having regard to historic delivery and expected future trends (NPPF paragraph 75). In our view, ST5 should be supported by a proportionate explanation of how any windfall allowance has been derived and why it remains robust when assessed against the higher LHN-led requirement and the plan period to 2041.
60. These issues are heightened by the role that strategic components play within the overall delivery strategy, including the assumed contribution from the Tendring Colchester Borders Garden Community. The supporting material at Preferred Options stage includes an assumed delivery contribution from the Garden Community within the plan period. While a DPD-led approach can provide an appropriate framework for a complex strategic location, the plan-making issue is whether there is sufficient certainty and timeliness in the assumed contribution to justify the level and phasing relied upon in the Plan's trajectory.
61. Strategic new settlement delivery is inherently complex and typically characterised by long lead-in times, infrastructure sequencing constraints, land assembly and delivery mechanism requirements, and market absorption limits. These are not criticisms of the Garden Community approach, but practical delivery characteristics that need to be reflected transparently in the Plan's trajectory and in the level of flexibility provided elsewhere in the allocations portfolio. Where a material component of supply depends on strategic delivery of this kind, it is prudent for the Plan to include sufficient additional

allocations capable of coming forward in parallel, so that housing needs can be met even where strategic outputs are delayed or build out more slowly than anticipated.
62. The key plan-making implication for ST5 is therefore that the Council should ensure the Plan does not become overly sensitive to the timing of delivery from a small number of strategic sources. Instead, ST5 should be supported by a balanced portfolio of sites, including additional deliverable options capable of contributing to housing delivery while also aligning with other Plan objectives, including environmental delivery.
63. Land at Brook Meadows is relevant in these terms. The Council is currently progressing the Site as a BNG allocation, and we support the principle of Brook Meadows performing a strategic biodiversity and green infrastructure role. However, the Plan's effectiveness also depends on whether reasonable alternatives have been tested transparently. In particular, the Council should assess whether a BNG-only approach represents the most justified and effective outcome when compared with a landscape-led residential option or a hybrid option in which a residential component is brought forward alongside a strategically significant BNG and green infrastructure function.
64. A hybrid approach has potential advantages in plan-making terms because it can secure long-term biodiversity delivery and management while also contributing to housing delivery and the overall resilience of the allocations portfolio. Importantly, this is not advanced as a commitment to any fixed quantum or delivery programme. It is advanced as a plan-making proposition that should be tested objectively through the Council's evidence base and Sustainability Appraisal, and, if selected, secured through criteria based requirements that protect sensitive assets, require appropriate buffers and management, and ensure that biodiversity outcomes are delivered and maintained in perpetuity.
65. For the purposes of improving the effectiveness of ST5 and its supporting trajectory, we recommend that the Council:
demonstrates transparently how lead-in times, annual delivery rates and phasing assumptions have been derived for proposed allocations, consistent with the NPPF expectation of realistic delivery trajectories for larger scale development (NPPF paragraph 77);
evidences any windfall allowance against the NPPF test of compelling evidence (NPPF paragraph 75), particularly in the context of a higher LHN-led requirement;

treats any plan-wide supply surplus as a realistic contingency margin to address slippage risk, rather than as an optional margin that can be eroded without consequence; and
ensures that the Site selection process and Sustainability Appraisal transparently test reasonable alternatives for Brook Meadows (BNG-only, residential and hybrid), so that the Plan secures both delivery resilience and measurable biodiversity outcomes through a coherent allocations' strategy.
66. On this basis, we support the direction of Draft Policy STS in anchoring the Plan's housing requirement to the Council's evidence. However, STS will only be demonstrably sound if it is underpinned by delivery assumptions that are explicit, consistent and realistic, and if it is supported by a sufficiently diverse and resilient portfolio of allocations. Testing Brook Meadows transparently against reasonable alternatives and securing the most justified and effective role for the Site through criteria-based allocation requirements, would assist in strengthening the Plan's effectiveness over the period to 2041.


Environment and Green Network
Draft Strategic Policy ST2 and related Green Network and Environment policies (GN1, GN2, GN5 and GN6, EN1-EN3, and EN5)
67. 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 and the green network. For plan-making purposes, ST2 is also important because it frames how the Council should balance environmental protection and enhancement against the need to maintain a deliverable and resilient plan strategy over the period to 2041.
68. In this context, Land at Brook Meadows, Tiptree is directly relevant. The Council's emerging approach identifies Brook Meadows as a preferred off-site biodiversity net gain location of high strategic significance within Draft Policy EN2. We are content, in principle, with Brook Meadows being identified for a biodiversity-led role in the emerging Plan, provided that the allocation approach is framed in a way that secures deliverability and long-term management.
69. A key plan-making issue is that a BNG allocation must be more than a map designation. If Brook Meadows is to perform a strategic BNG function, the Plan needs to be clear on what success looks like and how it will be secured in perpetuity. This includes clarity on:

the intended habitat creation and enhancement outcomes; how those outcomes align with the Council's wider nature recovery priorities; how the land will be managed long term; and how delivery will be funded, monitored and enforced. Without those hooks, the allocation risks being aspirational rather than effective.
70. The evidence prepared for the Site indicates that Brook Meadows has the potential to deliver meaningful habitat enhancement and creation through a coherent land management strategy. This includes the retention and enhancement of existing habitat features and the creation of new habitat types where appropriate. The Plan should therefore ensure that the policy framework positively enables the Site to deliver these outcomes in a planned way, including through a clear requirement for long-term stewardship arrangements.
71. The Green Network policies GN1 and GN2 should be applied to reinforce this delivery focus. Where Brook Meadows is identified as a strategic biodiversity and green network asset, the Plan should require that proposals (or delivery mechanisms) for the Site are underpinned by a clear management plan and that the Site's function as part of the wider green network is protected and enhanced. This is consistent with the Council's stated intention, through EN2, to prioritise locations capable of delivering the best gains for biodiversity.
72. Policies GNS and GN6 are also relevant because they provide the policy pathway for protecting and strengthening ecological networks and securing effective management of green infrastructure assets. In plan-making terms, those policies should be translated into allocation criteria for Brook Meadows that secure, at minimum:
the protection of sensitive ecological areas and appropriate buffering;
habitat creation and enhancement as the primary structuring principle;
appropriate access arrangements where compatible with biodiversity objectives; and
binding long-term management and monitoring arrangements so that gains are maintained, not eroded over time.
73. Draft Policies EN1 to EN3 and ENS should operate in a similarly practical way. EN3's emphasis on securing measurable biodiversity net gain and applying the mitigation hierarchy is supported in principle. The key plan-making point is that where the Council identifies a preferred off-site BNG allocation, the Plan should also specify the mechanisms through which delivery is secured, including how baseline, targeting, monitoring and long-term management will operate. Policy ENS is relevant because it

reinforces the need for environmental objectives to be embedded into delivery, rather than being left as aspirational requirements that can be diluted at implementation stage.
74. Finally, while Brook Meadows is identified as a preferred off-site BNG site, that should not automatically preclude the Plan from transparently testing reasonable alternatives for the Site. The Site is already recorded in the assessed site pool with promoted uses including housing and green infrastructure, and the Plan should therefore test whether a BNG-only approach represents the most justified and effective outcome when compared to a hybrid option where biodiversity delivery remains the primary structuring principle but a landscape-led residential component is brought forward in parallel, subject to clear safeguards and long-term stewardship.
75. On this basis, the Environment and Green Network policy suite is capable of supporting a sound approach to Brook Meadows, but its effectiveness will depend on whether the allocation is framed with sufficient clarity and delivery mechanism to secure the intended biodiversity outcomes in perpetuity, and whether the Plan transparently tests whether a hybrid approach could deliver both strategic biodiversity benefits and a contribution to housing delivery without unacceptable harm.


Growth and Opportunity Areas and Proposed Allocations
Strategic approach to allocations and the case for Land at Brook Meadows, Tiptree

76. 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 coherent and deliverable portfolio of sites. It is therefore the principal mechanism for ensuring the Plan is effective and capable of meeting 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.
77. This allocation task is particularly important because the Preferred Options Plan is anchored to a materially higher housing requirement than the historic adopted Local Plan requirement used for monitoring purposes. As set out elsewhere 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

adopted annual requirement of 920 dwellings per annum. The allocations portfolio must therefore be calibrated to the higher delivery challenge and should not rely on narrow headroom or optimistic assumptions that would only remain robust if measured against the lower historic requirement.
78. The Council's latest five-year housing land supply position indicates a marginal position above five years. That position relies in material part on windfall delivery assumptions and other supply components which, while capable in principle of contributing to delivery, introduce sensitivity to the assumptions applied and to performance over time. The plan making implication is not that windfalls should be excluded, but that the allocations portfolio should be sufficiently resilient such that slippage in windfalls, lead-in times or build-out does not translate into under-delivery against the Plan's higher requirement.
79. The Preferred Options Plan also relies on strategic components, including the Tendring Colchester Borders Garden Community, with an assumed contribution within the plan period. Strategic, infrastructure-led delivery can be subject to programme risk, governance and market absorption constraints. The Plan should therefore avoid over reliance on any single strategic component and should include a realistic contingency margin supported by a broad portfolio of sites with varied lead-in profiles and delivery characteristics.
80. In that context, the Council's approach to proposed allocations should seek to optimise multiple plan objectives rather than allocating sites for a single outcome by default where reasonable alternatives exist. This is directly relevant to Land at Brook Meadows, Tiptree (SLM Site ID 10132), which is already within the assessed site pool and is recorded as a site promoted for both housing and green infrastructure.
81. The Council is currently progressing Brook Meadows as a preferred off-site BNG location within Draft Policy EN2, identifying its strategic significance as high. We support the principle of the Site performing a strategic biodiversity and green network role, and we agree that a plan-led approach to off-site BNG delivery can be beneficial where it secures the "best gains" and long-term stewardship rather than leaving BNG delivery to piecemeal outcomes.
82. However, the allocation decision for Brook Meadows should not be treated as binary by default. The plan-making question is whether a BNG-only allocation is the most justified and effective use of the Site when tested against reasonable alternatives, including:
a biodiversity-led allocation (as currently envisaged);
a landscape-led residential allocation; and

a hybrid allocation in which biodiversity delivery is secured as the primary structuring principle, but a residential component is brought forward in parallel where it can be achieved without unacceptable harm and with clear safeguards and long-term management.
83. This matters in practical allocations terms for two reasons. First, the Plan is required to meet a higher housing requirement over a long plan period and must therefore maintain delivery resilience and contingency. Secondly, Brook Meadows has the potential, in principle, to deliver strategic biodiversity outcomes through habitat enhancement and creation, but that potential does not necessarily depend on the Site being sterilised from any other use. A hybrid approach could, subject to robust safeguards, secure long-term biodiversity enhancement and management while also contributing to housing delivery, thereby supporting the Plan's effectiveness and resilience.
84. The key is that any allocation pathway selected for Brook Meadows must be deliverable and enforceable in practice. If the Council proceeds with a BNG allocation, the allocation framework should include clear requirements for the delivery and long-term management of habitat outcomes, monitoring and maintenance arrangements, and the mechanism by which biodiversity units will be generated, secured and managed in perpetuity. A map-based designation alone will not be sufficient to ensure the Site delivers its intended strategic role.
85. If the Council considers, through transparent assessment, that a residential or hybrid role is appropriate, the allocation should be framed with clear criteria to ensure that biodiversity objectives remain primary, sensitive areas are protected and buffered, and any built development is landscape-led and mitigation-led. This approach would allow the Council to integrate housing delivery and biodiversity delivery rather than treating them as competing objectives, while still ensuring that the environmental role identified for the Site is secured through binding requirements.
86. 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 for Brook Meadows:
Ensure that Brook Meadows (SLAA Site ID 10132) is transparently tested through the Sustainability Appraisal and site selection process against reasonable alternatives, including BNG-only, residential and hybrid options, with clear reporting of the reasons for selection or rejection.

Calibrate the allocations portfolio to the higher LHN-led requirement and maintain a realistic contingency margin, rather than relying on narrow headroom, sensitive windfall assumptions or optimistic build-out trajectories.
If Brook Meadows is retained as a BNG allocation, frame the allocation with explicit delivery and stewardship requirements so that biodiversity outcomes are secured in perpetuity and are demonstrably deliverable.
If the assessment demonstrates that a hybrid approach is justified and effective, progress Brook Meadows as a mixed allocation with criteria-led requirements securing a landscape-led structure, avoidance and mitigation of ecological effects, and long-term management, while enabling an appropriate residential contribution as part of a comprehensive plan-led solution.
87. In summary, the soundness of the Preferred Options Plan will depend on whether the Proposed Allocations deliver a portfolio that is genuinely capable of meeting the housing requirement over the plan period, with sufficient flexibility and contingency to manage delivery risk, while also securing strategic environmental outcomes. Brook Meadows is already identified by the Council as a preferred location for strategic BNG delivery. The Plan should now ensure that the Site's role is determined through transparent reasonable alternatives testing and, whichever role is selected, that the allocation framework is drafted to secure deliverability and long-term stewardship in practice.

see attached

see attached

1.1 This representation on the Colchester Local Plan Regulation 18 ('the Draft Local Plan' or 'OLP') is submitted by Ceres Property on behalf of the landowner and Denbury Homes Ltd. (developer), and in respect of land south of Old House Road, Great Horkesley ('the Site)

1.2 The Site is under option to Denbury Homes Ltd. for development. Representation have been made throughout the Local Plan process to date, but at present the site remains unallocated and outside of the proposed settlement boundary of Great Horkesley.

1.3 Alongside the Local Plan process, Denbury Homes are also engaging with the Council through the pre-application process, with an intention to submit a full planning application later this year.

1.4 This representation considers the wider context of housing need in Colchester, and the approach of the current OLP to addressing this. It then considers the Spatial Strategy and the role of Great Horkesley within this, before going on to discuss the Site and the opportunity it presents to support wider Local Plan objectives.

1.5 A Site Location Plan is provided at Appendix A.

2. HOUSING NEEDS

2.1 The country is in the midst of a housing crisis. The consequences of this are manifold and negative, with wide-ranging social, economic and health impacts across England.
2.2 At the national level, the housing crisis manifests through homelessness, overcrowding, unsuitable and poor-quality housing, unaffordability and associated impacts on public expenditure and economic performance.
2.3 Most recent national statistics regarding statutory homelessness cover the quarter April to June 2025 and identified that whilst there had been some small improvements in overall figures, there remains an estimated 42,470 households assessed as homeless.
2.4 Further national analysis undertaken by charities includes people in temporary accommodation and various forms of hidden homelessness then this figure increases to at least several hundred thousand people homeless in England on any given night. This figure is understood to have increased over the last year, despite the recognised quarterly decrease in statutory homelessness acceptances.
2.5 Regardless of the specifics of these figures, they is clearly a significant issue that which reflects trends in high private rents, constrained social housing supply, welfare reforms, and cost-of-living pressures that limit the ability of at-risk households to sustain accommodation.These housing pressures contribute directly to homelessness risk and to the duration and cost of temporary accommodation placements.
2.6 On top of this, there continues to be national issues in respect of overcrowding and the quality of existing housing.
2.7 A lack of housing in areas of high demand constrains labour mobility, affects the formation and growth of businesses and hampers the ability of employers to recruit and retain staff.
2.8 Public services such as the NHS, police and schools have experienced recruitment and retention difficulties linked to high housing costs and limited availability of suitable accommodation.
2.9 Evidence indicates that Colchester City Council's administrative area is far from immune to these national pressures, with local market signals indicative of a housing shortage. Colchester City Council's Housing and Homelessness Summary - year end 2024 to 2025 and the Council's Key housing needs statistics suggest these include high house-price-to-income ratios and rising housing need.

2.10 Colchester City Council and its housing management partner (Colchester Borough Homes) report significant levels of homelessness and temporary accommodation use. Recent data includes the following.

In 2024/25, there were 1,563 new homelessness cases assessed in Colchester.
During the same year, 693 people required emergency accommodation at some point, illustrating the scale of immediate housing crises locally.
As at March 2025, 449 households were living in temporary accommodation in Colchester, up from 326 the previous year, indicating a marked increase in reliance on short-term housing solutions.
2.11 These figures suggest that, despite some national reductions in statutory homelessness, Colchester is experiencing substantial and growing demand on its homelessness services.
2.12 Colchester's Housing and Homelessness Summary for 2024/25 also reports that new affordable housing delivery remains insufficient to meet identified needs, with only 128 new affordable homes delivered between 1 April 2024 and 31 March 2025.
2.13 In terms of access to the private housing market, median house prices in Colchester significantly exceed local incomes, and private rents have risen faster than wages in recent years, placing both home ownership and private renting beyond the reach of many lower- and middle-income households.
2.14 In summary, there is clear evidence that the housing crisis at the national level also impacts Colchester. Indeed, evidence to suggest the impact is more acute in the borough than at the national level. This gives rise to a number of substantial concerns and potential harms to the local community, for the reasons set out above.
2.15 In considering the impact of housing delivery (or the impact of failing to deliver housing) the plan making process, (including Sustainability Appraisal) should account for the social and economic harms that can result from a lack of housing, and the benefit that addresses shortages has the potential to deliver for the local community.
2.16 The NPPF places great emphasis on seeking to address housing shortages. It requires that plans seek to meet objectively assessed needs for housing and to significantly boost the supply of homes. Providing a spatial strategy that, as a minimum, seeks to meet Colchester's identified housing needs is therefore essential to a sound Local Plan. But furthermore, boosting the housing land supply in Colchester, and doing so through a cogent strategy for growth, has the potential to deliver significant social and economic benefits to the local community. Benefits associated with providing homes include reduced homelessness and housing instability; greater
choice and flexibility for renters and buyers; shorter commutes and stronger local communities; better health, stability, and educational outcomes; increased economic productivity and labour mobility; more inclusive, balanced growth across the area.


Summary

2.17 Given all of the above, we consider it essential the strategy for delivering homes includes allocation of a variety of sites, as well as an overall provision that seeks to exceed the absolute minimum requirement and afford flexibility and contingency where it may be required across the Plan period (such as sites not delivering as many homes and/or as quickly as anticipated).
2.18 For further context, a Local Plan that proposes the delivery of 21,106 against a total minimum need of 20,800 homes equates to a buffer of just 1.1%, or 306 homes. This therefore provides very little contingency for delayed or non-delivery. This is particularly concerning when significant reliance is placed on strategic growth allocations, and the Tendring Colchester Border Garden Community which are dependent on the delivery of strategic infrastructure which could easily suffer as a result of changes to funding allocations for example.

2.19 We also note that the Sustainable Appraisal has not tests higher total housing requirements to formally understand the implications this could have in better meeting affordable housing needs or other infrastructure requirements.

3. POLICY ST3: SPATIAL STRATEGY

3.1 This section of this representation concerns Policy ST3 (Spatial Strategy), and its recognition of Great Horkesley as a medium settlement specifically.

3.2 The draft Spatial Strategy confirms the Council's intentions to direct growth in Colchester to the most sustainable and locations in the urban area or close to, and then beyond this allocated an appropriate level of growth to large, medium and some small settlements based on the opportunities and constraints of each settlement. The Council recognise the ability of such an approach to ensure the long-term viability of services and facilities in these locations which may otherwise be lost.

3.3 Within the associated settlement hierarchy, Great Horkesley is defined as a medium settlement. This is in recognition of the proximity of the village to the Colchester urban edge, proximity to the A12 and the range of services and facilities in the village.

3.5 Whilst we support this approach in principle, and the allocation of additional housing to Great Horkesley accordingly, we consider that the village has the capacity to accommodate increased housing growth, particularly where there are sites available which could deliver such growth in accessible locations with little to no wider harm that could not be mitigated through the proposed development, such as the site the subject of this representation.
3.6 In terms of the policy specifically, we propose further recognition within it that not all settlements within the same tier of the hierarchy will be equally sustainable to accommodate growth, and that their sustainability is not solely down to the characteristic of the settlement itself but also the accessibility of larger centres from them. Consequently, a settlement such as Great Horkesley, which is in very close proximity and easily accessible from accordingly, the main Colchester urban area should be considered more sustainable than other settlements of a similar size but significantly further away from the urban area.

4.1 The site is circa 6.45ha and located to the north of Great Horkesley and to the west of the A134 and south of Old House Road. It is also located to the west of residential development at The Crescent.
4.2 There are footpaths on both sides of the A134 which provides pedestrian and cycle connections to facilities and services to the south including village hall, public house, retail units, pre-school and primary school.

4.3 There are bus stops in close proximity to the site providing services into Colchester City Centre and to Sudbury.
4.4 Colchester railway station is approximately a 10 minute drive from the site which provides frequent services into London Liverpool Street, Ipswich, Norwich and Clacton-on-Sea. The site is thus extremely well connected and provides opportunities for active travel.
4.5 To the south of the site is Aldercar Wood which is subject of a Tree Preservation Order (TPO), there are however no TPO trees on the site. The site is not within a conservation area but there is a Grade II listed building, Rookery House, located to the north east.
4.6 The site is located between the north and south settlement boundaries of Great Horkesley. The site is also located in EA Flood Zone 1.

4.7 Whilst the site does not meet the existing settlement boundary of Great Horkesley, as shown on the draft Local Plan excerpt below, we do consider that the current boundary (Figure 1) is not reflective of the true settlement shape and extent of development. There is little justification for splitting the settlement when there is continuous development between the two.
4.8 It can be seen that the formal boundary is split in two, when in fact there is consistent development between the two and thus the joining of these two boundaries would include around 85 existign residential properties. It would also in turn then present a number of opportunities for modest extensions to the settlement without encroachment towards other settlements or on land which would otherwise have a much greater impact on the wider landscape and surrounding rural character.

4.9 We therefore propose that the settlement boundary for Great Horkesley is amended to include the full extent of the existing built area, as well as the site the subject of this representation, as indicated in Figure 2.

Proposals

4.10 Early assessment of site constraints and opportunities has identified the ability for the site to be able to deliver:

110 new homes
o 74 market homes
o 33 affordable homes (30%)
o 3 self-build plots
New substantial areas of open space and green network throughout site
Defined buffer to existing Grade II Listed Rookery House
Minimum 10% biodiversity net gain
New links from the site to the existing green infrastructure network via The Crescent and Footpath 34
Green buffer round entire site

4.11 An indicative masterplan and associated layout for the site are provided at Appendix B and C respectively. This demonstrates the ability of the site to provide the above benefits.

4.12 The Council's own DLP evidence base (Strategic Land Availability Assessment (SLM)) confirmed that there are no significant constraints to the development of the site, and advised that the site was excluded from allocation purely based on its proximity to the village's facilities when compared with other sites.
4.13 Taking into account previous commentary within this representation regarding the need for the Council to plan for more than just the minimum number of new homes, then it is proposed that this is considered further based on its standalone credentials and opportunities as opposed to simply considering against other sites in the context of a set housing need.

Overview

4.14 The Site is not subject to any significant constraints that would render it unsuitable for residential development.

4.15 The Site would represent a logical, proportionate addition to Great Horkesley in a contained location which follows the existing pattern of development.

4.16 When considering additional sites, the site the subject of this representation should be considered in high regard and proposed for allocation accordingly.


5. OTHER DEVELOPMENT MANAGEMENT POLICIES

5.1 We do not support the requirement set out in Policy LC1 which requires for all applications for major development sites to be accompanied by a Landscape Visual Impact Appraisal (LVIA). A full LVIA is extensive and it is not uncommon for a Landscape Visual Appraisal or other appropriate assessment of landscape impact to be more proportionate whilst still allowing for a suitable assessment of landscape impact.
5.2 We therefore propose that the wording of this policy is relaxed to include flexibility on the specific type of assessment that is required.
5.3 Proposed Policy GNS requires that the Natural England standard of 8 hectares per 1000 head of population be applied where it is necessary to provide alternative greenspace as the result of a Habitat Regulations Assessment. It is proposed that the policy wording is reviewed to allow flexibility in the application of this ratio, as opposed to an arbitrary calculation. It is our view that the provision of SANGs should consider the quality of the provision, overall site location and other variables in determining an appropriate provision for any site.

5.4 Furthermore, sites in Colchester do of course make RAMs contributions to seek to manage recreational disturbance pressures, so again, this is a factor that should be taken into account alongside the Natural England ratio which may not consider local factors such as this.

5.5 In respect of proposed Policy NZ1, we consider the Council's dismissed alternative suggestion to be more appropriate. Building Regulations set out a number of requirements in relation to the sustainability of new buildings and by nature of them comprising national requirements, they are evidently deemed appropriate. It is therefore unreasonable for the Council to propose requirements beyond these without appropriate justification or flexibility.
5.6 The first point (a) of Policy PC7 is also unnecessarily prescriptive in requiring that the primary public open space for any new major residential development on greenfield sites should be located centrally within the site. We are mindful that new public open spaces can be important areas for existing residents as well as new, and can serve important roles in encouraging integration. In some instances, a new area of public open space will be a key public benefit for a development so it is important that there is flexibility to ensure that this can be located in the most appropriate location for each specific site.

l. INTRODUCTION

1.1 This letter comprises a representation to the Colchester Local Plan Review Regulation 18 consultation. It has been prepared by Ceres Property on behalf of Gleeson Land - the promoters of land north of Bromley Lane, North East Colchester.
1.2 The land the subject of this representation is outlined in red on the accompanying plan (Ref: 410_067310) (Appendix A). It comprises 46.62 ha (of which 41.74 ha falls within Colchester City Council) situated within a wider area of land proposed for allocation in the Regulation 18 Preferred Options Local Plan under Policy PP9. This representation relates to the land under Gleeson Land's control only, but has been informed by work being undertaken regarding the wider land allocation alongside.

1.3 Gleeson are working alongside Gladman, who are the other party with a major land interest in the allocation, to prepare a cohesive masterplan for the site as a whole.This would support the progress of individual planning applications without risk to the overall objectives of the allocation as a whole. The latest version of the respective Masterplan Framework (Appendix B) is appended to this representation.
1.4 You will note they support and have directly informed the proposals for the land the subject of this representation.

1.5 Despite the above, the 46.62 ha being promoted by Gleeson Land remains deliverable in its own right, as detailed later in this representation.
1.6 In preparing these representations, regard has been had for Chapter 3 of the National Planning Policy Framework (NPPF) which relates to 'plan-making'.

1.7 Paragraph 15 of the NPPF promotes a plan-led system, and that succinct and up-to-date plans should provide a positive vision for the future of each area; a framework for addressing housing needs and other economic, social and environmental policies; and a platform for local people to shape their surroundings.
1.8 Paragraph 16 states that Plans should:

a) be prepared with the objective of contributing to the achievement of sustainable development;

b) be prepared positively, in a way that is aspirational but deliverable;

c) be shaped by early, proportionate and effective engagement between plan- makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

e) be accessible through the use of digital tools to assist public involvement and policy presentation; and

f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).
1.9 As set out at paragraph 36, local plans are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are 'sound'. The test for soundness as set out within the NPPF requires that Plans are:

a) Positively prepared

b) Justified

c) Effective

d) Consistent with national policy

1.10 By way of background to the Council's preparation of the emerging Local Plan, it is acknowledged that the Council's current five year land supply is increasingly marginal.
1.11 In February 2026 the existing Adopted Section 1 Local Plan becomes 5 years old, and the housing requirement within it will accordingly be out of date for the purposes of calculation of five year housing land supply as set by NPPF paragraph 232.

1.12 The housing land supply annual requirement will therefore become approximately 1,300 homes per annum in line with the standard method, as opposed to 920 homes per annum within the existing adopted Local Plan. Over a five year period this will add 1,900 homes to the required supply plus the required buffer.
1.13 The Council acknowledge this requirement at paragraph 3.36 of the Regulation 18 Consultation document, confirming that the requirement for 20,800 new homes over the plan period is a mandatory target which must be planned for. Taking into account the homes to be delivered through the Tendring Colchester Borders Garden Community and windfall sites, the Council assert at paragraph 3.40 the need to plan for a minimum of 11,089 in order to meet the housing needs of Colchester (emphasis added).

2. THE SITE

2.1 The Site currently comprises cultivated agricultural land, split into four distinct parcels divided by hedgerows/field boundaries. There are existing minor power lines crossing the site approximately north to south, and east to west. These are shown on the accompanying Opportunities and Constraints Plan. There is also a gas main running north to the south through the site.
2.2 The eastern boundary of the site is defined by Salary Brook, with some small areas at risk offloading in association with this. Salary Brook also demarcates the authoritative boundary between Colchester City and Tendring District. To the north, the site meets further agricultural land. To the west/northwest the site meets existing residential development accessed from Welshwood Park Road and Woodlands, and additional land proposed for allocation towards the A137. An area of ancient woodland (Welsh Wood) insets the site in the eastern corner and then the southern extent of the site meets Bromley Road and Salary Close.

2.3 There are no listed buildings within direct proximity of the Site. The closest are Grade II Listed Hill Farmhouse and surrounding buildings which are south of Bromley Road and separated from the site by existing Salary Brook, existing vegetation and existing development along Bromley Road.
2.4 Due to its consistent use as an agricultural field, the ecological baseline of the Site is low. Despite this, the ecological value of the vegetated field and site boundaries should not be understated, and will therefore be duly considered for protection and enhancement as part of any future development proposals.
2.5 The Site is predominantly located within EA Flood Zone 1 (land at least risk of tidal and fluvial flooding), though some land area along the southeastern border are within Flood Zone 3, as well as being at risk of surface water flooding too.
2.6 More generally, the suitability of the site as a location for growth, and specifically for that of a significant scale, has already been recognised by the Council through its proposed allocation under Policy PP9.
2.7 The land adjoins the urban area of Colchester City and bus stops along Bromley Road provide regular bus services to the Hythe where there is a railway station, supermarkets and other retail and employment opportunities, Colchester town centre (including stops close to North Station), and through to Stanway too where there are a number of additional retail and leisure facilities. More local facilities are just a short walk (approx. 400m) from the site along Bromley Road, including a local conveniences store, a nursery, Hazlemere Infant and Junior schools and Colchester Academy.
2.8 The site's constraints and opportunities have been mapped on the accompanying plan prepared by FPCR. Existing utilities routes are easily managed through rerouting and grounding, and the overall extent of the site affords ample land for the protection of a buffer for the adjacent ancient woodland to the west, as well as the avoidance of development in areas at risk of flooding which in turn provides an opportunity for the extension and enhancement of the Strategic Biodiversity Area alongside the adjacent watercourse along the southern boundary. Existing public rights of way through and around the site are also considered as opportunities for enhanced site access and connectivity. There are therefore no significant physical constraints to the sites development.

2.9 Some specific site constraints and opportunities have been considered in more detail below.

Access and Public Rights of Way

2.10 Engagement with Essex Highways has confirmed a scope and design for an access which would be suitable for the proposed development. The site would require a single access only, and is proposed to be taken from Bromley Road. Onward connectivity into surrounding areas and the rest of the proposed allocation will be in the form of pedestrian and cycle connections only.
2.11 Public Footpath 113 dissects the Site but is well-positioned to be retained and incorporated into future proposals to retain and enhance onward connectivity from the site to surrounding development and countryside to the northwest and southeast. The proposals will also provide opportunities for connection into Footpath 114 which runs along the northeastern boundary.

Arboriculture

2.12 There are no Tree Protection Orders on the site itself, but Welsh Wood Ancient Woodland meets the site in the southwestern corner. There is a requirement for an overall buffer for this woodland, as well as for the closest individual veteran trees within it. These have been set at fixed constraints from the outset. A Preliminary Arboricultural Appraisal identified a number of other high quality trees along the existing field boundaries, and along Bromley Road. These have been highlighted on the accompanying Constraints and Opportunities Plan and tree retention in these areas will be a priority.
Ecology

2.13 A preliminary ecological appraisal has also been undertaken for the site. The appraisal highlights that the Site is of the nature that would allow for a number of animal species to be supported.

Though further survey work would therefore be required as part of any future application, the early proposals have been designed to consider the existing value of the site, as well as the opportunities for maximising Biodiversity Net Gain and habitat opportunities alongside future development. The siting of the site along Salary Brook presents a unique opportunity in this respect.
Flood Risk

2.14 Areas of flood risk are limited to the boundary of the site along Salary Brook. An area of surface water flooding also runs along the internal field boundary and associated ditch. These areas have been excluded from proposed development areas and will instead be used for open space, drainage mitigation and ecological enhancement areas.
2.1 s The Council has of course undertaken a Sequential Test for all proposed allocations and this forms part of the Local Plan Evidence Base. This assessment confirms that only very small proportions of
the allocation are in areas of risk, and acknowledges that the requirement for an initial masterplan will ensure that development is kept outside of these areas of risk. It is on this basis that the site "passes" the Council's test.


3. POLICY ST3: Spatial Strategy

3.1 Gleeson Land support the Council's spatial strategy, which seeks to direct growth to the most sustainable and accessible locations in the urban area. Prioritising these locations, whilst of course supplemented by smaller allocations across lower order settlements, is inevitably a sustainable strategy in that it ensures development will be delivered in the most accessible locations, and where there is already an established principle of development in the immediately surrounding area.

3.2 Land at Bromley Road, as allocated through Policy PP9, supports this strategy given its location on the edge of the existing Colchester Urban Area, and in a highly accessible location.


4. POLICY PP9: North-East Colchester

4.1 Policy PP9 sets out a number of objectives for the wider site allocation, and thus it is important that any development of the smaller parcel the subject of this representation supports these objectives.

4.2 The policy recognises the importance of an overarching masterplan in ensuring that any phased development contributes to the overall objectives, and ensures that all are fully achieved across the allocation as a whole. Gleeson Land are working closely with other developers to prepare a masterplan, with the latest draft supporting this representation, with the expectation of formally submitting this to the Council for approval prior to the submission of any future planning applications. In the meantime however, in support of the promotion of this smaller parcel, each of the allocation objectives are considered in turn below.

The latest Development Framework considers that this part of the site could deliver around 750 homes across two main phases, based on a density of 35 dwellings per hectare and taking into account land reserved for landscaping, drainage and open space. When considered as part of the wider allocation, this is proportionate and supports the overall delivery intentions of the policy.

This representation is accompanied by an Access Appraisal and Transport Assessment Scoping Note which has been reviewed with Essex Highways through early pre-application discussions. We also provide a Pre-Application Response Note which follows up on the initial advice received. Most importantly, the engagement process has confirmed that a suitable single access can be achieved from Bromley Road for around 750 new homes.
The proposed access has been the subject of a Road Safety Audit too to provide further reassurance. Access opportunities for other parts of the allocation will be considered at the relevant time, but would be most appropriately accessed from Harwich Road and St John's Road, and thus independently of this part.


Proposals for active and sustainable travel will be developed through more detailed proposals and a full Transport Assessment, but pre-application discussions have identified an opportunity for a new Toucan crossing on Bromley Road to enhance pedestrian safety around this particular access point. Furthermore, the existing public rights of way are being considered as key opportunities within the Masterplan Framework of both this site and the wider allocation site, to ensure connectivity within the allocation as well as with surrounding land. The site is well-placed to access existing bus services.

At present, wider masterplan work has identified that the most suitable location for a local centre would be in the northwestern part of the allocation and the proposals for this more southerly part of the site would not hinder the delivery of this. Enhancements to existing public rights of way that cross the A12 would also ensure pedestrian and cycle connectivity to this centre from all parts of the allocation area.

At present, wider masterplan work has identified for a strategic open space would be most suitable in the northern part of the allocation. Nevertheless, the site the subject of this representation demonstrates appropriate space to provide open space to immediately serve homes in this part of the allocation, and contribute to the wider green network planned throughout area as a whole.

Detailed landscape proposals would be developed in due course, but the early Masterplan Framework ensures that a buffer is provided to Welsh Wood, and also to Salary Brook where it is proposed that this buffer could then in turn provide an opportunity for enhanced biodiversity and open space. Other early landscaping proposals include the retention and enhancement of existing landscape features along the field boundaries.

The site the subject of this representation does not meet Bullocks Wood. It does however neighbour Welsh Wood and an appropriate buffer will therefore be designed into proposals to ensure its protection.

An extensive buffer to the Salary Brook is proposed, and will provide generous space for its conservation and enhancement. The site drainage strategy will be carefully designed to manage the amount and quality of any surface water which may enter the existing watercourses.

Preliminary arboricultural assessments undertaken by Gleeson highlighted the key constraints in relation to the land under their control. This includes Welsh Wood Ancient Woodland and other trees and hedgerows of value within and around the site. These, with their associated buffers, have been set as fixed constraints to inform early site layout and land use proposals.

Extensive areas of open space are proposed on key site boundaries and will provide flexible spaces for planting and sensitive integration into the landscape.

Gleeson will be happy to work with other landowners and the Council to agree this. To date, key connectivity opportunities have been factored into early site design work.

Existing public rights of way within and around the site will be retained, and there may be opportunities for enhancement also. Furthermore, the site will be designed to encourage connectivity into these existing routes, and allow for permeability across the site and wider allocation as a whole.

Given the location of the designated heritage assets closest to this part of the site, it is expected that the proposals will be able to be designed in a manner which ensures that any harm to their wider settings is minimised and/or negated.

Gleeson will undertake this engagement as part of any future planning application.

Any future drainage strategy will consider this further.

This will be dealt with as part of any future planning application.

This will be considered through the development of a detailed drainage strategy for the site, and through design measures to minimise water consumption.

Gleeson are working with other parties with an interest across the allocation to ensure that land and space is reserved for such uses in the most suitable locations.

These surveys will be factored in the programme of species surveys that will be required prior to the determination of an application, as directed by Preliminary Ecological Appraisal work.

Gleeson are working with other parties in the preparation of a masterplan for the entire allocation area to meet this objective. The latest version of this document supports this representation and demonstrates the ability of the Site to complement the wider intentions of the allocation.

4.3 More generally, and whilst not a formal point of objection at this stage, we do consider it to be worth noting that there are a number of requirements within this policy which would ordinarily be addressed through standard development management policies set out elsewhere in the plan, and other national legislation. There may therefore be an opportunity to simplify the policy in areas.

5. POLICY GN5: Suitable Alternative Natural Greenspace

5.1 Proposed Policy GN5 requires that the Natural England standard of 8 hectares per 1000 head of population be applied where it is necessary to provide alternative greenspace as the result of a Habitat Regulations Assessment. It is proposed that the policy wording is reviewed to allow flexibility in the application of this ratio, as opposed to an arbitrary calculation. It is our view that the provision of SANGs should consider the quality of the provision, overall site location and other variables in determining an appropriate provision for any site.

5.2 For site specific allocations, such as PP9, a provision of this nature, when taken with other land requirements set out through the policy, could have significant implications on viability.
5.3 Furthermore, sites in Colchester do of course make RAMs contributions to seek to manage recreational disturbance pressures, so again, this is a factor that should be taken into account alongside the Natural England ratio which may not consider local factors such as this.

6. SUSTAINABILITY APPRAISAL

6.1 As part of this Regulation 18 Consultation, a Sustainability Appraisal Report has also been provided for review and comment. This latest report considers the site-specific policy text following earlier "policy-off' appraisals. This ensures that mitigation sought through the proposed policy wording is therefore now reflected in the assessment.
6.2 The majority of assessments remain the same, apart from Economic Growth which improves to a minor positive, from a minor negative. Biodiversity and geodiversity also improves to a minor negative from a significant negative. We support this further consideration of these site constraints.
6.3 Whilst the assessment remains unchanged, we continue to have concerns over the recording of a significant negative effect for the site in relation to SA objective 2 - Efficient use of land. This is based on the loss of greenfield land and Grade 2 and Grade 3 agricultural soils. The majority of agricultural land around Colchester is in fact Grade 2 or 3 and thus not considered a scarce resource. Additionally, some areas are Grade 1 and therefore it would be expected that development in these locations would be seen to have the most significant negative impact but there is no greater

6.4 Given that this would apply to the majority of allocations for the City, it is considered disproportionate to consider this as a significant negative effect and a categorisation as a minor negative effect would better reflect this constraint.

7. SUMMARY

7.1 Overall, Gleeson Land strongly support the proposed allocation of land north of Bromley Road. Whilst they do not control all land within the allocation, they are working closely with other landowners to ensure all of the objectives set out in Policy PP9 can be achieved.
7.2 More specifically, this representation has set out the extent to which their land can meet the objectives independently, and not hinder the delivery of the remainder of the allocation, emphasising the opportunity for new homes to be delivered over short timescales.

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