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

Braiswick Residents Association objects to Policies LC1 and LC2 as they rely on broad mitigation rather than clear safeguards to protect landscape character. The policies do not adequately address the cumulative impact of development on sensitive landscapes or settlement edges. Without stronger criteria or constraints, there is a risk that development will erode local character and harm valued landscapes, contrary to national planning policy

The open views to the south of Abberton and Langenhoe are an important contribution to the coastal protection zone and their retention is supported.
The first views of the coastal estuaries are quite memorable and precious.
Equally these views are important from the coastal towns and Dengie peninsular

I am writing to formally object to the proposed development of 900 houses on land north of Park Lane, Langham. This proposal conflicts with the Colchester Local Plan (2017–2033) – Section 2, Chapter 2: Vision and Approach, and the following policies:

• Policy ST3 – Spatial Strategy: Langham is designated as an “Other Village,” suitable only for limited growth. A scheme of this scale is disproportionate and contrary to ST3.
• Policy ST7 – Infrastructure Delivery and Impact Mitigation: The development lacks adequate infrastructure provision and fails to mitigate adverse impacts on local services and transport.
• Policy ST8 – Place Shaping Principles: The proposal disregards local character, landscape setting, and community identity.
• Policy EN6 – Conserving and Enhancing the Historic Environment: The development would harm the setting of heritage assets within Langham.
• Policy LC1 – Landscape: The scheme would irreversibly alter the rural landscape and sever the visual link between village and countryside.
• Policy PP37 – Development in Rural Areas – Langham: Large-scale development is incompatible with Langham’s designation and rural character.

The application is inconsistent with the Local Plan’s vision for sustainable, proportionate growth and should therefore be refused.

Thank you for considering my objection.

Kind regards,
Justin Scofield

a,b, and c are too vague. How are they measured?

Why is West Mersea referred to as a principal urban conurbation (6.4)?! We are on an Island - can't get much more coastal than that. One suspects that a whoever put West Mersea on that list had no understanding of West Mersea.
There is something about Mersea - the air-change across the Strood, the sky colours and light, the sounds of seabirds and waves on the shore - that creates " the tranquillity, features and patterns that contribute to the landscape character and local distinctiveness of the area", and which must be safeguarded or strengthened.

The National Landscape team broadly supports policy LC1. The need for the completion and submission of a Landscape and Visual Impact Assessment for all major applications in line with the most current Landscape Institute guidelines. We recommend that the policy is amended to state that an LVIA or a Landscape Appraisal as a minimum should also be required for applications for isolated homes in the countryside.

We are also seeking the following modification to criteria (b):
The scale, design, materials (including colour), lighting and landscaping measures.......landscape.

WBPC supports this policy and particularly agrees with “Development must comply with all the following criteria: a) Development must safeguard or strengthen tranquillity, features and patterns that contribute to the landscape character and local distinctiveness of the area, protect rural openness and sense of place and protect natural landscape features ..........”
Therefore, it is difficult to justify the inclusion of Policy PP44: Land off Colchester Road, which is wholly located in an area considered to be a valued landscape, as evidenced in WBPC Neighbourhood Plan, Policy PP12 and Map PP12 and paragraph 15.3.3. See also Viewpoint2SheetA.jpg.

West Bergholt Parish Council generally supports this policy but would propose the following amendment:
"All proposals and associated land use change or land management must demonstrate that they are informed by, and are sympathetic to, the landscape character and qualities of the locality. A Landscape and Visual Impact Assessment (LVIA) is required for all major developments including those of at least 50 housing units and must be prepared in accordance with Landscape Institute guidelines.”

The development proposed under policy PP23: Land East Dawes Lane falls within the Coastal Protection Belt and is productive farm land.
Policy LC1 (Landscape) seeks to protect and enhance landscape character, the setting of valued landscapes, and the coast. Additional sewerage and wastewater from new development can cause indirect and cumulative harm through degraded watercourses, estuaries, and coastal waters, impacting habitats, landscape character, and visual amenity. Where these impacts are not
properly assessed or mitigated, compliance with LC1 cannot be demonstrated, and the objectives of ST2 (Environment, Green Network and Waterways), ST3 (Infrastructure Delivery and Impact Mitigation), and EN3 (Biodiversity and Net Gain) are also undermined.
The estuarine and coastal areas of the island are covered by international & local nature conservation designations – Coastal Protection Belt (CPB) - Site of Special Scientific Interest (SSSI) - Special Protection Areas (SPA) – National Nature Reserve (NNR) – Ramsar Site - the Essex Estuaries Special Area of Conservation. (SAC), Marine Conservation Zone (MCZ) and the National Character Area 81 – Greater Thames Estuary (NCA) These designations are a significant constraint on settlement expansion, particularly when in-combination their effects are considered.
Appeal decisions support this approach. In APP/A1530/W/21/3285769, the Inspector concluded that development within the Coastal Protection Belt on Mersea Island would conflict with policies protecting the character of the coast and countryside, even when the site was not immediately adjacent to the coast, noting the broader context of National Character Area 81 and the CPB. This establishes clear precedent that coastal and estuarine landscapes are highly sensitive to development impacts, including cumulative and indirect environmental effects.
13
Further the Landscape Character Assessment report states on pages 262 & 279 “New development within the area should be avoided.”
Conclusion:
The Local Plan cannot be considered sound unless it explicitly assesses and mitigates additional sewerage and wastewater impacts on these sensitive landscapes, habitats, and designations, ensuring compliance with LC1, EN3, ST2, and ST3.

The proposed site is agriculture land in the centre of the village. Surely this should be kept to help the country be less reliant of imported crops. A very large housing estate would not be sympathetic to the landscape and character of the village in any way. There are currently open fields with footpaths with a wide aspect, and lovely countryside to walk and enjoy. Ribbon development along the current roads is the only way that any increase in housing would suit and could be sustained within the village without causing too much major disruption.

We refer to your plans/consultation for the development of 900 houses on agricultural land north of Park Lane, Langham, Essex.

We both as residents of Langham, Essex object in the strongest terms possible to these ridiculous and unsustainable plans/consultations.
We find the whole matter very badly though out by Colchester City Council with no regard to the implications and subsequent consequences
which are numerous and alarming,

The most relevant policies which we have to comment are as follows;

1. Chapter 2- Vision & Approach.

Points 2.6 & 2.7, The matter of water levels will increase dramatically with waste water and sewerage from 900 houses. The water table levels are
already high in Langham with flooding a regular problem. if you research these issues you will see the problem that already exists. Anglian Water
will take years to put a decent sewerage plant in place let alone manage to fund it.
Point 2.13 & 2.20, In your consultation you state quite clearly the need to double natural greenspace in the future. We can see from the map/plans that
apart from space for a cricket pitch there are no plans or evidence of any greenspace.
Point 2.14, You again clearly state your policy is to create 1300 new homes per year in and around Colchester. So why build 900 homes in one place in a year? This goes against your own policy.

2. Policy ST7- Infrastructure Delivery & Impact Mitigation,

Point 3.65, This states that all the categories must be implemented. We seriously doubt if they can and will be implemented. Also we very much doubt
that sufficient contributions will be received from Developers. There are no plans for infrastructure or mentioned what these will entail. The scale of
another 900 houses means that shops, schools, doctors, will be needed.

3. Policy ST8- Place Shaping Principles.

We advise that you will not be protecting the natural environment. Drainage will be a major concern, already Langham has problems with this issue.
All the streets currently have no lighting at all and we cannot see this changing making it very dangerous and not safe in non daylight hours.
Transport in the village will become a major issue with no thought to developers traffic, excessive number of cars in village on roads already not suitable for todays traffic, There will be further issues with the A12 traffic junction to Langham from the Colchester direction, already a tight dangerous
junction.

4. Policy LC1 - Landscape.

Point 6.5, This in no way ever happen if 900 houses built.

5. Policy PP37 - Land north of Park Lane, Langham.

We cannot see that any of the points in a to p would be implemented or sustained if 900m houses are built.

We advise that the cumulative impact of all the issues, challenges, and uncertainties raised above means that the site allocation is very unlikely
to prove desirable in compliance with the NPPF deliverability definitions.

We both fully endorse and support Langham Parish Council's response to the Regulation 18 Local Plan Consultation involving the proposed 900
new houses in Langham.

In summary we object to the plans to build 900 houses in Langham and find this totally unsuitable, unsustainable, and just not viable regarding
Transport, Environment, Infrastructure, Funding issues and non-compliance in every respect of Colchester City Council's Principles.

If any housing has to be implemented in Langham we suggest initially maximum 300 houses in the short term, then further 300 in 5 years time, and last 300 five years after that. Even this is too much for such a small village.

Yours faithfully, Colin Strutt and Valerie Stone

I am writing to formally object to the proposed development of 900 new dwellings north of Park Lane in Langham. This proposal conflicts with the objectives and policies set out in the Colchester Local Plan (2017–2033), in particular Section 2, Chapter 2: Vision and Approach, as well as the following relevant policies:

Policy ST1 – Health and Wellbeing: This policy fails to properly consider the negative consequences for the health and wellbeing of existing Langham residents

Policy ST3 – Spatial Strategy: Langham is designated as an “Other Village,” where only limited and proportionate growth is intended. The scale of the proposed development is wholly disproportionate and far exceeds what could reasonably be described as modest expansion, placing it in direct conflict with Policy ST3.

Policy ST4 – Development in the Countryside: A development of approximately 900 homes would fundamentally alter Langham’s role as a rural village.

Policy ST7 – Infrastructure Delivery and Impact Mitigation: The proposal does not include for suitable infrastructure to be delivered to support such a significant increase in population.

Policy ST8 – Place Shaping Principles: The development does not positively contribute to the village’s identity or integrate sensitively with the existing community.

Policy EN6 – Conserving and Enhancing the Historic Environment: The scale and nature of the development would undermine the village’s historical character.

Policy LC1 – Landscape: The proposals would result in a permanent and damaging alteration to the surrounding countryside, severing the visual and physical relationship between the village and its rural landscape.

Policy PP37 – Development in Rural Areas – Langham: Largwe-scale housing developments are incompatible with Langham’s rural designation and village status. The proposed scheme is therefore inappropriate in both scale and character for this location.

I am disappointed in how the council has failed to ensure that the older population, like myself, can access the information regarding these developments, and then the ways in which to respond, Not everyone has access to the internet and it's only because my daughter told me about the development that I was made aware. I feel that the council was excluding my opinion and those of my generation.

This proposal fails to align with the Local Plan’s ambitions for sustainable and balanced development. On this basis, I respectfully urge that the application be refused.

I am writing to formally object to the proposed development of 900 new dwellings north of Park Lane in Langham. This proposal conflicts with the objectives and policies set out in the Colchester Local Plan (2017–2033), in particular Section 2, Chapter 2: Vision and Approach, as well as the following relevant policies:

Policy ST1 – Health and Wellbeing: This policy fails to properly consider the negative consequences for the health and wellbeing of existing Langham residents, many of whom chose to live here because of the open green spaces, access to wildlife, and strong connection to the surrounding rural environment. The proposed development area would eradicate these features, replacing valued open views and natural landscapes with dense housing, to the clear detriment of residents’ quality of life.

Policy ST3 – Spatial Strategy: Langham is designated as an “Other Village,” where only limited and proportionate growth is intended. The scale of the proposed development is wholly disproportionate and far exceeds what could reasonably be described as modest expansion, placing it in direct conflict with Policy ST3.

Policy ST4 – Development in the Countryside: This policy emphasises that development should not harm settlement identity, valued landscapes, countryside character, or visual amenity. A development of approximately 900 homes would fundamentally alter Langham’s role as a rural village, eroding its distinct identity and resulting in the irreversible loss of its countryside setting.

Policy ST7 – Infrastructure Delivery and Impact Mitigation: The proposal does not demonstrate that adequate infrastructure will be delivered to support such a significant increase in population. In particular, the impacts on local services, facilities, and the transport network have not been satisfactorily addressed.

Policy ST8 – Place Shaping Principles: The development fails to respect or reflect the established character, landscape setting, and sense of place that define Langham. As proposed, it does not positively contribute to the village’s identity or integrate sensitively with the existing community.

Policy EN6 – Conserving and Enhancing the Historic Environment: The scale and nature of the development would cause harm to Langham’s historic environment, adversely affecting heritage assets and undermining the village’s historical character.

Policy LC1 – Landscape: The proposals would result in a permanent and damaging alteration to the surrounding countryside, severing the visual and physical relationship between the village and its rural landscape.

Policy PP37 – Development in Rural Areas – Langham: Large-scale housing developments are incompatible with Langham’s rural designation and village status. The proposed scheme is therefore inappropriate in both scale and character for this location.

I would also like to add that the way residents are required to respond to the Local Plan (or even to know about it) alienates many, who like myself are of the older generation, and find navigating websites and in particular the consultation documents confusing or may not have online access at all. It is only because I am being helped by my daughter that I am in a position to lodge my objection, otherwise my voice would go unheard (which makes me feel this is part of the Council’s plan).

In summary, this proposal fails to align with the Local Plan’s ambitions for sustainable and balanced development. On this basis, I respectfully urge that the application be refused.

Thank you for considering my objection.

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.

I have an objection based on what appears to be an error in the Colchester Landscape Charater Assessment 2024. Area B7, Langham Farmland Plateau, is only rated as having Medium Value. B7 includes Bullock Wood SSSI, a nationally rare landscape, therefore according to Appendix A, A.3 this makes the area Higher Value. "Higher value – The LCA has a multiple sensitive attributes and values relating to natural, and/or cultural and/or perceptual factors; or has one or more sensitive attributes and values that are particular important (for example it represents a nationally rare landscape type, or forms part of a nationally designated landscape/area). PP9 is partly under area B7 and partly area A6, Ardleigh River Valley, which is already rated Higher Value under the LCA. Therefore as LC1 says "landscape character areas with 'high' inherent value and sensitivity as per Appendix A of the Colchester Landscape Character Assessment 2024, are valued landscapes. Development within valued landscapes will only be permitted where it would protect and enhance the characteristics that contribute towards its character". NPPF paragraph 187, quoted in 6.6 backs this up. This is yet another reason why PP9 is unsuitable for development.

I would imagine Dawes Lane is grade 1 farmland why is it being considered?
I do not agree that solar panels should be put grade I farm land. They should be on the roofs of domestic and commercial buildings. Every warehouse should double as a solar farm!

not achievable

Criteria (b should be amended to include lighting - see below

(b) The scale, design, materials, landscaping measures and sensitive lighting are appropriate and would lead to an enhancement of the character of the landscape.

While Colchester Zoo supports the Council’s general approach to landscape protection, as currently drafted within policy LC1, the proposed policy is in parts overly prescriptive and inflexible.
Requiring all major developments to submit a Landscape and Visual Impact Assessment, strictly adhere to the Colchester Landscape Character Assessment 2024, and meet multiple detailed criteria risks disproportionate application, particularly on sites where landscape sensitivity is low or impacts are minor. This approach does not sufficiently reflect the flexibility and proportionality expected by the NPPF (paragraphs 16, 32 and 36), which supports evidence‑based, deliverable policies that allow decision-makers to consider site-specific mitigation and design-led solutions.

wish to register my opposition to the Local Plan and the planned construction of 900 new homes north of Park Lane in Langham. This scheme is at odds with the principles and policies outlined in the Colchester Local Plan (2017–2033), specifically Section 2, Chapter 2: Vision and Approach, and the following provisions:

•     Policy ST1: Health and Wellbeing: The policy ignores the crucial feature of a village, especially Langham, which has plenty of green open spaces and opportunities to connect with wildlife and the calm environment. A calm, green village is beneficial to mental health, physical health and people's wellbeing. The plans to strip the fields and build many houses, acts against ST1 and puts people's health at risk. Langham will no longer be a peaceful open green village for an escape of a busy life in cities or in general

•     Policy ST3 – Spatial Strategy: Langham is a quiet village and should remain that way as they aren't many of these left. New policies do not align with ST3, Langham cannot handle the expansion discussed.

•     Policy ST4: Development in the Countryside: The nature of the proposed development is completely at odds with this policy as 900 new homes would destroy Langham as a village and it would completely lose it’s rural nature.

•     Policy ST8 – Place Shaping Principles: The development overlooks the unique qualities, landscape, and identity of the local community. The beauty of a village is its greenery and uniqueness. Building 900 houses, ruins its identity and transforms a lovely village into a mass housing estate.

•     Policy EN6 – Conserving and Enhancing the Historic Environment: The project would negatively impact the historic assets and heritage of Langham. Something we should take pride in preserving as an old country with a large history.

•     Policy LC1 – Landscape: The plan would permanently change the countryside and break the visual connection between the village and its rural surroundings.

•     Policy PP37 – Development in Rural Areas – Langham: Large developments are unsuitable for Langham’s status and rural nature.

My objections are not limited to the policies specifically referred to above, many of my reasoning for objections are similar, as the action to build 900 houses has as same overall impact. Overall, the application does not support the Local Plan’s goal for balanced and sustainable growth and should therefore be declined. As a young (17yrs) member of Langham community, it makes me deeply upset at the possibility of the plan to go through as my home is being wrecked for unnecessarily developments that the quiet lovely village I live in will not be able to support. And as environmental issues are being more prominent over these last years to see continuation of stripping up the green from this country and planet is greatly disappointing. I beg that the opinions of the residents are being listened to and acted upon and that as a youth, you will not destroy the countryside and leave the consequences in the hand of us.

Regulation 18 Consultation – Response to Policy on Development on Agricultural Land (Grade 1 and BMV)
Policy text consulted on:
“Development on Land classified as Agricultural Grade 1 (except for renewable energy projects) will not be permitted unless a landscape strategy, which would compensate for the loss or harm, is secured or where there are overriding public benefits arising from the development.”
Summary position
I object to the policy’s allowance for development on Agricultural Grade 1 land under any circumstances and to the proposed exception for renewable energy projects. I recommend (i) a clear presumption against development on Grade 1 land without exceptions, and (ii) a policy approach that directs renewable energy away from Grades 1, 2 and 3a (i.e., Best and Most Versatile—BMV—land) to lower-quality land, brownfield, rooftops and industrial sites. This aligns with national policy’s emphasis on recognising the value of BMV land and preferring poorer-quality land where development of agricultural land is demonstrably necessary.
Detailed representations
1) Grade 1 land is an irreplaceable natural asset; loss cannot be “compensated” by landscaping
Grade 1 soils are the highest quality agricultural resource. Their productive capacity and soil functions (structure, depth, organic matter, drought/wetness regime) cannot be recreated by a “landscape strategy”, so mitigation of soil quality loss is not feasible in kind. National guidance places specific weight on protecting Best and Most Versatile (BMV) land—Grades 1, 2 and 3a—and advises using poorer-quality land instead where significant development of agricultural land is necessary. [southandvale.gov.uk], [gov.uk]
The NPPF (Dec 2024) requires planning policies to recognise the economic and other benefits of BMV land and, where significant development of agricultural land is necessary, to prefer poorer quality land. The current policy wording, which permits development on Grade 1 where “overriding public benefits” are claimed or “compensated” by landscaping, risks undermining the Framework’s precautionary approach to BMV protection. [assets.pub...ice.gov.uk]

Requested change:
Amend the policy to prohibit development on Grade 1 land without exceptions, removing the “landscape strategy” and “overriding public benefits” caveats. This would reflect that soil quality loss is irreversible in planning terms. [southandvale.gov.uk]
2) Renewable energy should not take precedence over Grades 1, 2 or 3a
We support the transition to net zero, but site selection matters. National policy and recent ministerial statements make clear that developers should, where possible, use previously developed/brownfield/industrial land and, if agricultural land is necessary, prefer poorer quality land while avoiding BMV where possible. This applies particularly to large-scale ground-mounted solar. [questions-...liament.uk], [charlesrus...echlys.com]

The National Policy Statement for Renewable Energy Infrastructure (EN‑3, designated 2024) expressly states that proposals should prefer poorer quality agricultural land and avoid BMV where possible, and that applicants should justify site choice and consider continued agricultural use/colocation only where appropriate. None of this creates an automatic primacy of renewables over BMV; rather, it embeds a sequential, impact‑led approach. [charlesrus...echlys.com]
Requested change:
Delete the explicit exception for renewable energy on Grade 1 land and insert a criterion that renewable energy schemes must (a) avoid Grades 1, 2 and 3a unless robustly demonstrated alternatives do not exist, and (b) exhaust brownfield/rooftop/industrial options first, consistent with EN‑3 and ministerial guidance. [charlesrus...echlys.com], [questions-...liament.uk]

3) Food security and climate resilience justify stronger protection of BMV land
The UK Food Security Report 2024 stresses that domestic production is a key component of resilience, with around 60–62% of all food sourced domestically and ~75% self‑sufficiency for foods that can be grown here; maintaining soil and land quality underpins that resilience. The report also highlights that agricultural productivity and environmental conditions (soil, water, pollinators) are critical constraints that can be degraded by unsustainable land use changes. [gov.uk], [gov.uk]
Recent policy commentary and evidence underline the strategic importance of safeguarding the best agricultural land for long‑term food security, especially amid climate and geopolitical risks. Government’s Written Ministerial Statement (15 May 2024) explicitly emphasises protecting BMV and prioritising poorer‑quality land for solar deployment. [questions-...liament.uk]
Requested change:
Add explicit food security wording to the policy justification, linking the protection of Grades 1, 2 and 3a to the UKFSR 2024 evidence base and the need to preserve domestic productive capacity as a matter of resilience. [gov.uk]
4) Evidence base and definitions
For plan-making clarity, the policy should:
Define BMV as Grades 1, 2, and 3a (Agricultural Land Classification). [southandvale.gov.uk]
Require that where land is mapped as Grade 3 (undifferentiated) or uncertain, applicants provide a site‑specific ALC survey to distinguish 3a (BMV) from 3b before allocation/consent. This follows best practice from Natural England and professional bodies. [gov.uk], [soils.org.uk]

Suggested replacement policy wording (trackable draft)
Policy X: Protection of Best and Most Versatile (BMV) Agricultural Land
X.1 Development on Agricultural Grade 1 land will not be permitted.
X.2 Development on BMV land (Grades 1, 2 and 3a) will be permitted only in exceptional circumstances where it is robustly demonstrated that:
a) No reasonably available alternative site of lower agricultural quality (including Grades 3b–5), previously developed land, or rooftops/industrial land can meet the need; and
b) The proposal minimises the permanent loss of agricultural soils, secures a Soil Resource and Management Plan, and delivers measurable, site-specific environmental gains without undermining soil functions.
X.3 Renewable and low‑carbon energy proposals must avoid BMV land (Grades 1, 2 and 3a). Proposals on BMV will be refused unless criteria X.2(a–b) are satisfied and a compelling alternative‑sites assessment demonstrates that no feasible non‑BMV and brownfield solutions exist.
X.4 Where land is identified as Grade 3 (undifferentiated) or where ALC data are uncertain, applicants must submit a site‑specific ALC survey to distinguish sub‑grades 3a/3b.
Reasoned justification: The NPPF requires plans to recognise the economic and other benefits of BMV land and, where significant development of agricultural land is necessary, to prefer poorer-quality land. Protecting BMV supports long‑term food security, climate resilience and the sustainable management of soils. National energy policy (EN‑3) and ministerial statements emphasise the use of brownfield/industrial land first and avoiding BMV where possible. [assets.pub...ice.gov.uk], [gov.uk], [charlesrus...echlys.com], [questions-...liament.uk]
References to national policy and guidance (selected)
National Planning Policy Framework (Dec 2024): recognises the economic and other benefits of BMV and steers significant development of agricultural land to poorer-quality land; relevant to Chapter 15 and plan‑making provisions. [assets.pub...ice.gov.uk]
Natural England / Defra guidance: Guide to assessing development proposals on agricultural land (GOV.UK) and TIN049 define BMV (Grades 1, 2, 3a) and stress protection of BMV and soils; ALC is the only approved grading system and supports the need for site‑specific surveys. [gov.uk], [southandvale.gov.uk]
Energy NPS (EN‑3) & commentary: steer solar to brownfield/industrial, prefer poorer-quality land, and to avoid BMV where possible; require justified site selection and soil resource plans. [charlesrus...echlys.com]
Written Ministerial Statement (15 May 2024): emphasises protecting BMV and prioritising poorer-quality land for solar to balance energy security with food security. [questions-...liament.uk]
UK Food Security Report 2024 (Defra): underscores the role of domestic production, the ~60–62% overall domestic sourcing and ~75% indigenous self‑sufficiency, and the critical dependence on soil and environmental quality. [gov.uk], [gov.uk]

The clear definition of "valued landscapes" and their protection from development where it would not protect and enhance the characteristics that contribute towards its character is to be welcomed.

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.

See attachment

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.