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The beautiful history of West Bergholt is intertwined with the allotments, dating back to 1865 where the allocation of land was given to the poorer residents of the village to cultivate. In allotment history the most amount of land a single man could cultivate equated to a 10 rod measurement system which is used as a standard in many allotment sites throughout the UK today. The Allotments in West Bergholt on Chapel Road, and New Church Road are owned in trust as a charity registered number 219751. Therefore this should not be thought of as a new or even an existing area of open space, as it is not Council land. And as an aside should never ever be built on

See attached letter - Amendment to the Policies Map and Policy GN6 designation to exclude land from the identified open space allocation.

West Bergholt Parish Council generally supports this policy but is concerned that the time period referred to in “There is an identified excess provision within the catchment of the facility and no likely shortfall is expected within the plan period” and “in the area either at the time of the proposal or be likely to result in a shortfall within the plan period” is very limited.

Because the WMNP will be out of date and unlikely to be updated because of the cost and time of doing revisions every 5 years will our designated Local Green Spaces be protected in future? If so how will they be logged if no new NP?

The proposals map shows grazing land at School Road, Langham owned by Essex County Council as being 'open space'.

The open space designation is assumed to be in error, and we would be grateful if it is possible to correct this and remove the open space designation.

The grazing land has been fenced and used for well in excess of 10 years for grazing, and has been let on a horse grazing tenancy. No public access is allowed over the land, and it has been continuously used for horse grazing.

Attached is a plan showing the grazing land edged red (overlaid on proposals map), and photographs of the site.

It is requested that clarity is provided in the reasoned justification that proposals affecting playing fields and other outdoor sports facilities will be assessed against Policy CS4: Sports Provision as this policy is specifically intended for assessing development proposals affecting outdoor sports facilities. The scope of open space is often interpreted to include outdoor sports facilities especially playing fields. As the criteria in policies GN6 and CS4 are different there is a risk of potential confusion about which policy should be applied to outdoor sports facilities and developers may exploit this by making the case that GN6 applies if this offers them more potential for compliance with the Local Plan than CS4.

I agree with the Policy, but not how you have applied it to the Local Plan allocation selections. In fact it seems to have been totally ignored. The inclusion of PP9 as an allocation fails point (b) as any development would result in the loss of an amenity for St John's residents, and a green network, as well as change the character of the general area. If you really mean what is said in the last paragraph of the Policy, "Additionally, development that would result in the loss of any small incidental areas of open space, not specifically identified on the policies map but which contribute to amenity value and the character of existing residential neighbourhoods, and any registered common, heathland or village green or which contribute to Colchester's green network will not be permitted", then it follows that no development of PP9 will be allowed, so why is it included?

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.

This representation is prepared by Ceres Property on behalf of Eastern Counties Education Trust Ltd with respect of the Colchester City Council Preferred Options Local Plan Regulation 18 Consultation.

Our client has land interests at a Site located to the west of Oxley Parker Drive, to the north of Colchester, Essex. The Site area comprises 1.2ha of land and can be identified on the accompanying Site Location Plan.

Background
The Council’s Local Plan is in two sections. Section 1 is the strategic plan for North Essex, adopted on 22nd February 2021 and covers strategic policies for Braintree, Colchester and Tendring including housing requirements.

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. The Council’s current five year land supply is increasingly marginal.

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.

It is therefore clear that shortly the Council will not be able to demonstrate a five year housing land supply. It is critical that the Council allocates sufficient land for housing to meet the Government's requirement to significantly boost the supply of homes, as enshrined in national planning policy. The standard method for calculating housing land supply produces a minimum annual target that local authorities must treat as a floor, not a cap, ensuring that plans deliver at least this level of growth while addressing local needs and affordability pressures.

The Site
The Site comprises a c.1.2 hectares parcel of vacant land, rectangular in shape from north to south. The Site is bound by the former Colchester Rugby Club to the north and west, estate housing along Oxley Parker Drive to the east and Tower Lane and housing beyond to the south. The Site is relatively featureless and flat is generally well enclosed from trees and hedgerow on the northern and southern boundaries, with views into the Site from housing to the east and glimpsed views from the field to the west.

The Site currently has no vehicular or public access into the Site, with Oxley Parker Drive terminating at the eastern boundary of the Site. The Site currently has no public access for pedestrians or vehicles, with Oxley Parker Drive concluding at the eastern boundary, and Tower Lane on the southern boundary being the nearest public pathways. Tower Lane is a Public Right of Way (Ref: BR 233 314).

In the current adopted Local Plan the site is identified on the policies map as Public Open Space as can be seen on the policies map extract below.

To the west and northern boundaries the site adjoins the Colchester Northern Gateway site. The reserved matters application for this site, relating to the erection of 330 residential units was submitted on 5th December 2025 (application ref. 252596). It is shaded in red on the extract below.

Policy DM17 of the current Local Plan seeks to protect and enhance the existing network of green links and open spaces with a presumption against development that results in the loss of open space unless re-provided or equally compensated for elsewhere in the local area.

The Site falls with the main urban area of Colchester, towards the northern edge of the city just inside (south) of the A12. The Site is within a short walking and cycling distance to a range of services, facilities and amenities, with public rights of way abutting the southern boundary and the nearest bus stop with regular services throughout Colchester and to the City Centre less than 5 minutes’ walk from the Site on Mill Road. The Site is 10 minutes cycle north of Colchester Train Station which runs regular direct trains to London Liverpool Street and the wider eastern region. The Site is also 5 minutes’ drive south of Junction 28 of the A12. The Site is this in a highly sustainable location for residential development.

Furthermore, the Site is wholly located within Flood Zone 1 (land least at risk of tidal and fluvial flooding) and experiences minimal risk of surface water flooding.

Whilst it is noted that in the latest draft of the Local Plan the site is proposed for inclusion within the Northern Gateway Opportunity Area under draft Policy OA4, its current designation of open space and separate ownership means there is a lack of commercial incentive or likelihood of delivery. Our client would be supportive of the Site’s inclusion within this Area, on the basis of its allocation for residential development alongside open space.

Relevant Planning History
Alongside previous promotion, the Site was the subject of a refused outline application (ref. 193145) and dismissed appeal (ref. APP/A1530/W/21/3277732) for the construction of 40 dwellings with all matters reserved.

The Inspector at that time determined that the redevelopment of the Site for residential development would have a harmful impact on the provision of open space within the local area and it would therefore conflict with the development plan as a whole. This was on the basis that the Unilateral Undertaking did not guarantee the re-provision of the loss of the Site elsewhere and conflicted with (then emerging) Policy DM17 of the Local Plan (Retention of Open Space and Recreation Facilities).

The Inspector noted at paragraph 26 of their decision that:
‘The fact that access to the public has not historically been granted does not mean that this will not be forthcoming in the future. Indeed, there is no substantive evidence before me to indicate why the site could not be made accessible in the future. Therefore, this is not a consideration which outweighs my findings.’

The previous appeal decision was issued in July 2022, and it is clear that considerable further time (almost 4 years) has now elapsed with no further progress or certainty on how any open space provision could or will be provided on this site. Further changes have also arisen in terms of national planning policy, including the extent of overall housing needs which are also highly material to the consideration of this site.

In this period further progress has been made on the adjoining Colchester Northern Gateway site. The land to the west and north of the Site benefits from the following planning permission (Ref: 190665) – the reserved matters referred to above falls within this wider outline:

Hybrid planning application - Outline application for healthcare campus (5ha)of up to 300 older people's homes (C3),4,300sqm private acute surgical hospital (C2),(1,200sqm.) medical centre (D1),3,600sqm, 75-bed care home (C2),up to 55742sqm offices (B1a);up to 350 homes (C3), with ancillary retail & food & drink of up to 1000m2 of retail (A1),up to 500m2 of food and drink (A3),digital network of ultra fast broadband;2 points of vehicular access from public highway, pedestrian boulevard & community green(4.5ha).All matters apart from access to be reserved in relation to outline elements of proposals. Detailed consent for a 1st phase of infrastructure to include the creation of a pedestrian boulevard and associated landscaping, and a renewable energy centre & heat distribution network

Detailed applications and build out of this site has been progressing, and therefore the surrounding context of the site also continues to evolve.

The Site will therefore eventually be enclosed by development on all sides, and it is consider the promotion of the site for a combination of residential and open space use would provide a more valuable contribution to the local community than at present, of which there is little to none.

There is presently no public access to the Site, and no requirement for the Site to be brought into open space use, despite its designation as such. Furthermore, there is no viable funding mechanism available to bring the site forward for public open space use.

Consequently, the open space designation cannot be sustained and should not be taken forward as part of the current Local Plan review process.

Site Assessment
Within the adopted Local Plan, the Site falls within the main urban are of Colchester City where the principle of development is supported. As set out above, the Site is however designated as public open space.

The Site is not currently accessible to the public and thus serves little to no utility, function or amenity to existing and future residents of the local area. The Site will be enclosed on all sides by predominantly residential development in the short term, placing the Site in a heavily residential area with its character reflecting this. Given the emerging development coming forward the Site would be put to far greater use providing a source of good local housing for local residents.

The NPPG at Paragraph: 017 Reference ID: 37-017-20140306 confirms, in the context of Local Green Space designations that “Designation does not in itself confer any rights of public access over what exists at present. Any additional access would be a matter for separate negotiation with land owners, whose legal rights must be respected.” The same is also applicable in this situation, there are no public rights of access to the land.

With this in mind, it is proposed that the allocation of the site for residential and open space would ensure the Site presents a suitable and deliverable opportunity for both uses.

The Site provides the opportunity to deliver high quality development that combines residential use with enhanced open space, with it being proposed that approximately half of the site could be dedicated to each use.

Such an approach would bring forward much needed housing in a sustainable location while also opening up and improving the remaining site area for public or enhanced open space use.

The Site has no deliverability constraints. It lies within Flood Risk Zone 1 (lowest flood risk) and is not within a Conservation Area, nor is it adjacent to any designated or non designated heritage assets.

Any proposals for residential development will retain and enhance boundary vegetation and strengthen landscaping along the eastern and western edges where gaps currently exist. Any scheme will carefully consider the relationship to existing housing to the east on Oxley Parker Drive and to future development to the west, ensuring adequate separation distances and adopting a sensitive approach to scale and massing along these boundaries.

Appropriate buffers will be implemented to mitigate potential impacts on nearby residents to the east, addressing noise, overlooking, loss of privacy, and perceived bulk. There is sufficient space on site for open space, drainage attenuation, and Biodiversity Net Gain (BNG) as part of a comprehensive landscaping, open space, and green infrastructure strategy to support residential development.

The Site does not sit within any environmental designations and is located in a highly sustainable area for residential development, where the principle of development is supported.

The Site is thus deliverable. It can accommodate a suitable mix of tenures, including affordable housing, while delivering open space, landscaping, BNG, green infrastructure, and drainage attenuation. Delivery could occur within five years, contributing to Colchester’s housing supply in the early years of the forthcoming plan period.

The Site is available for development, currently held by a willing owner as vacant grassland, with no legal constraints hindering delivery.

Overall, the Site could support around 40 units at a density of 35–40 units per hectare; to accommodate open space, a capacity of approximately 25–30 units is proposed, alongside a significant area of open space. The site should be allocated on this basis.

Summary
The current Public Open Space designation applied to the land west of Oxley Parker Drive is no longer justified or reasonable to retain within the emerging Local Plan.

The Site is in private ownership, has no lawful public access, and there is no mechanism or funding available to bring it into open space use. As a result, while the Site is technically designated as open space, it provides no practical recreational, environmental or community function. The Council’s continued reliance on this designation therefore cannot be sustained through the Local Plan Review and is not considered to meet the tests of soundness.

Given the City’s housing requirement the Council must identify additional, deliverable, and sustainable residential sites to meet needs in the early part of the plan period. This Site can make an immediate contribution, being unconstrained, available, and in a highly sustainable location aligned with the spatial strategy for growth.

Similarly useable open space that will benefit residents will also need to be delivered to accommodate growth.
The Site can deliver residential development alongside new, accessible and enhanced open space, it represents a significantly more effective and beneficial use of the land than the continuation of an undeliverable open space designation and the site sitting vacant.

For these reasons, the emerging Local Plan should therefore remove the Public Open Space designation from the Site and instead allocate the land for residential‑led development, incorporating publicly accessible open space as part of a comprehensive proposal. This will ensure the Local Plan is effective, justified, and deliverable and will assist Colchester in meeting both its housing and green infrastructure ambitions over the plan period.

Please do not hesitate to get in contact should any further information be of assistance.

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

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

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.

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

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

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

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