Only if TA for reasons aforementioned

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.

'Requirement 2: Fossil fuel free' gives no date for this to start. Will dates be added to this and other requirements or are they simply 'aspirations'? With no date there will be no compliance - this comment applies to all the requirements on housing.

This regulation is unnecessary and extremely expensive. The viability appraisals show that the cost over the plan period is £215m, money which could have been available for infrastructure funding.

There should be no need for regulation in any case because the economic incentives are right: better insulation and air tightness earns a satisfactory return through reduced heating bills.

If the Council really wants to spend £215m on net zero carbon housing instead of infrastructure then the choice should be explained clearly so residents can form an informed view.

West Bergholt Parish Council supports this policy in principle.

I write to confirm the statutory safeguarding position of the Ministry of Defence (MOD) in relation to
Colchester City Council’s preferred options local plan regulation 18 consultation document.
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a
statutory consultee in the UK planning system to ensure designated zones around key operational
defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites
are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in
conjunction with any other submissions that might be provided by other parts of the MOD.
Paragraph 102 of the National Planning Policy Framework (December 2024) requires that planning
policies and decisions take into account defence requirements by ‘ensuring that operational sites
are not affected adversely by the impact of other development proposed in the area.’ Statutory
consultation of the MOD occurs as a result of the provisions of the Town and Country Planning
(Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002
(DfT/ODPM Circular 01/2003) and the location data and criteria set out on safeguarding maps
issued to Local Planning Authorities by the Ministry of Housing, Communities & Local Government
(MHCLG) in accordance with the provisions of that Direction.
Copies of these relevant plans, in both GIS shapefile and .pdf format are issued to Local
Planning Authorities by MHCLG. An assurance review was conducted by the MOD in 2023
which confirmed that, at that time, Local Planning Authorities held the most recent relevant
safeguarding data. Any subsequent updates to those plans were then issued by MHCLG. If
there is a requirement for replacement data, a request can be made through the above email
address.
The Colchester City Council’s preferred options local plan authority contains and is washed over by a
safeguarding zone designated to preserve the operation and capability of the East 2 WAM Network.
Eastern 2 WAM (Wide Area Multilateration) Network is a new technical asset, which contributes to
aviation safety by feeding into the air traffic management system in the Eastern areas of England.
There is the potential for development to impact on the operation and/or capability of this new
technical asset which consists of nodes and connecting pathways, each of which have their own
consultation criteria.
The review or drafting of planning policy provides an opportunity to better inform developers of the
statutory requirement that MOD is consulted on development that triggers the criteria set out on
Safeguarding Plans, and the constraints that might be applied to development as a result of the
requirement to ensure defence capability and operations are not adversely affected.
To provide an illustration of the various issues that might be fundamental to MOD assessment carried
out in response to statutory consultation, a brief summary of the relevant safeguarding zone is provided
below. Depending on the statutory safeguarding zone within which a site allocation or proposed
development falls, different considerations will apply.
• Technical assets that facilitate air traffic management, primarily radar, navigation, and
communications systems are safeguarded to limit the impact of development on their capability
and operation. The height, massing and materials used to finish a development may all be
factors in assessing the impact of a given scheme. Developments that incorporate renewable
energy systems may be of particular concern given their potential to introduce large expanses
of metal or electromagnetic interference, which may be a particular issue where solar PV
systems are developed, or moving surfaces which may be visible to and detectable by radar
systems such as the blades of a wind turbine.
In addition to the safeguarding zones identified, the MOD may also have an interest where
development is of a type likely to have any impact on operational capability. Usually this will be by
virtue of the scale, height, or other physical property of a development. Examples these types of
development include, but are not limited to:
• Any development that would exceed a height of 50m above ground level. Both tall (of or
exceeding a height of 50m above ground level) structures and wind turbine development
introduce physical obstacles to low flying aircraft.
• Development, regardless of height, outside MOD safeguarding zones but in the vicinity of
military training estate or property.
The strategic growth site, Tendring Colchester Borders Garden Community land allocated has
elements that fall within the East 2 WAM Network statutory safeguarding zone, where any
development or change of use will trigger a MOD statutory consultation requirement.
The MOD notes the provisions within Policies Policy NZ1: Net Zero Carbon Development and Policy
NZ4: Renewable Energy.
The MOD has, in principle, no objection to any renewable energy development, though some
infrastructure enabling renewable energy production, for example wind turbine generators or solar photo
voltaic panels can, by virtue of their physical dimensions and properties, impact upon military aviation
activities, cause obstruction to protected critical airspace surrounding military aerodromes, or impede the
operation of safeguarded defence technical installations.
Where turbines are erected in line of sight to defence radars and other types of defence technical
installations, the rotating motion of their blades can degrade and cause interference to the effective
operation of these types of installations potentially resulting in detriment to aviation safety and operational
capability. This potential is recognised in the Government’s online Planning Practice Guidance which
contains, within the Renewable and Low Carbon Energy section, specific guidance that both
developers and Local Planning Authorities should consult the MOD where a proposed turbine has a
tip height of, or exceeding 11m, and/or has a rotor diameter of, or exceeding 2m.
Solar PV development which can impact on the operation and capability of communications and other
technical assets by introducing substantial areas of metal or sources of electromagnetic interference.
Depending on the location of development, solar panels may also produce glint and glare which can
affect aircrew or air traffic controllers.
The MOD request in order to provide a broader representation of MOD interests, and to ensure
prospective developers are aware of the implications of developing within an area containing MOD
safeguarded assets , that any emerging policy makes clear that, where an MOD assessment
indicates that a development would have a detrimental impact on the operation and capability of
defence assets or sites, that such an application would be refused or that conditions may be
attached to any consent that might be issued which may include the removal of permitted
development rights.
I trust this clearly explains our position on this update. Please do not hesitate to contact me should
you wish to discuss or clarify any issue raised in this letter.
C Waldron
Chris Waldron
DIO Assistant Safeguarding Manage

From Newmark Viability and Delivery Assessment Policies page 25
2. Requirement 2: Fossil Fuel Free
a) No new buildings shall be connected to the gas grid; and
b) fossil fuels must not be used on-site to provide space heating, domestic hot water or cooking
Note these conditions for Dawes Lane site PP23 did include no gas central heating, which we would certainly support and wonder why this is not more universal.

A small/medium sized builder might find there is a market for a property to have a log burner featured, I therefore dislike a policy which says that developer cannot install a log burner!

Our questions on this policy relates to cost and value. We feel a further explanation of exactly what is being delivered is warranted.

While we support the objective of reducing carbon emissions, the policy adds an estimated £215 million to development costs. Greater clarity is required on what this delivers, whether it represents value for money, and whether elements of this funding could more effectively be directed toward critical infrastructure deficits without undermining environmental outcomes.

If I have understood this correctly any new residential building should be able to produce enough electricity over the year to cover or exceed their annual usage, or the figure listed in 4., whichever is the greater. However if a developer can show that this isn't possible to do on site they can effectively pay a penalty to offset the shortfall and the money from this will pay for renewable energy production elsewhere to cover the shortage. Is that correct?

The mandatory use of electricity only for heating, lighting and cooking is a recipe for disaster. In the event of power cuts which could well be prolonged owing to the obsession with renewables, the likelihood of hypothermia and malnutrition for all ages, especially the very young and elderly, is very real. Risks compounded by the failure of the now digital telephones would prevent calling for help, batteries for mobiles could not be charged, etc, etc, etc. I does not bear thinking about.
An open fire would provide a lifeline. One per home should be permitted.

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

Policy NZ1 seeks all new buildings, including developments of one dwelling and above, to be designed and built to be Net Zero Carbon standard during in operation.

Bloor Homes recognises Local Planning Authorities legal duty to deliver carbon reductions through the planning process in line with the Climate Change Act (2008), including both the 2050 goal for a net zero carbon UK, and sharply-declining five-yearly carbon budgets between today and 2050; also reflected in the National Planning Policy Framework’s (2024) requirement for Plans to take a proactive approach to mitigating and adapting to climate change.

Bloor Homes acknowledges the aspirational approach to achieving progress on climate change and energy efficiency, but the new Local Plan needs to also acknowledge that these aspirations go well beyond current requirements and have consequential financial and land take considerations that have not been fully assessed in the evidence base. As such, allocations that the Council are depending on to deliver their housing requirement may become less viable or not deliver the quantum of development expected. Each site must be considered on its individual merits alongside the range of wider benefits the site will deliver. As such, any policy should include ‘where appropriate or possible to do so’ to provide the necessary flexibility to ensure sites come forward.

We object to Policy NZ1 as currently drafted. While we support the ambition to reduce carbon emissions from new development and the transition to net zero by 2050, the policy is overly complex, inflexible and insufficiently justified, and risks undermining the deliverability and viability of development across Colchester. The term Net Zero in operation is often banded around but the reality of all c.15,000 home allocations in this plan is extremely onerous and uncertain especially when set against a national picture that requires the transition to occur by 2050. See attachment.

Policy NZ1 requires all new buildings to be designed and built as Net Zero Carbon in operation. The Policy requires new buildings to be ultra-low energy, be fossil fuel free, generate renewable energy on-site and to at least match predicted annual energy use. The Policy provides technical requirements in respect of space heating demands and energy use intensity limits.

Richborough supports measures to encourage climate resilience, mitigation and adaptation, although requiring all buildings, including residential, to be Net Zero Carbon in operation is not supported as it is too onerous and not a national sustainability standard. For effectiveness and consistency, the policy should seek to use national sustainability standards where possible.

The Government’s Written Ministerial Statement (WMS) of December 2023 states that the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned building regulations.

The WMS clearly states that any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly costed rationale with evidence around impacts on schemes’ viability within the local authority area.

Richborough consider it critical for these parts of the Policy to be removed from the emerging LP and for Colchester to accord with the WMS by relying on the standards that are set and updated nationally through Part L of the building regulations and the forthcoming roll-out of Future Homes Standards.

Richborough notes that the Viability Assessment (2025) includes £7,500 per unit for Future Homes Standards and an additional 5-8% on build costs to achieve additional net zero initiatives. While the Viability Assessment has not concluded that these costs are unviable in the majority of scenarios, there will of course be instances where these requirements cannot be achieved and investors are discouraged from developing sites in the Council area.

Richborough does not consider it appropriate or reasonable to establish a requirement for renewable energy generation on-site. Whilst there is scope for some sites to deliver renewable energy generating initiatives, this will significantly hamper market attractiveness for some developers, particularly the small to medium sized housebuilders.

To ensure the policy is effective, Richborough suggests an amendment so the Policy refers to national standards in the form of building regulations and the emerging Future Homes Standard. This ensures a consistent, clear and readily understood requirement across the country, which will assist in boosting housing delivery.

The viability analysis submitted by Newmark provides an insufficient level of detail to allow it to be scrutinised. Consequently the viability conclusions cannot be relied upon, which fundamentally undermine the Council's Net Zero policy aspirations and affordable housing targets. A detailed report looking at the Newmark assessment has been separately submitted

Policy NZ1 requires all new-built development (both residential and non-residential) to be designed and built to be net zero carbon in operation. They must be ultra-low energy buildings, fossil-free, and generate renewable energy on-site to at least match predicted annual energy use. The policy was written prior to the emergence of the revised National Planning Policy Framework, December 2025, which includes Policy CC1: Planning for Climate Change.

Policy CC1 advises amongst other things that :

“Development plans should take a proactive approach to mitigating climate change and supporting the transition to net zero.”

It is evident from the Government's draft policy CC1, that the expectation is that development plans should support the transition to net zero, whereas Draft Local Plan Policy NZ1 & NZ2, mandates that all new development must be net zero carbon in operation. As policy NZ1 was prepared prior to the revised Framework, it could not have anticipated the Government's direction of travel, with regard to new build development and the achievement of net zero carbon. The Government’s position on net zero development has been clarified seeking a transition to achieving net zero. As such, Policy NZ1 & NZ2 should be redrafted, so as to be compliant with the emerging Framework, or be deleted from the Local Plan, and the transition to net zero left to the Building Regulations. The Building Regulations are themselves evolving, pushing for new development to have near-zero operational carbon through higher energy efficiency, low-carbon heating (like heat pumps), and renewable energy integration, with the upcoming Future Homes and Buildings Standard (2025).

As se out above while very little weight can be attached to the current consultation on the NPPF careful attention will need to be given to the outcomes of the consultation and the final document that is adopted. With regard to standards related to carbon emission and energy efficiency standards consideration will need to be given to PM13 which states that other than standards for accessibility, water efficiency and nationally de-scribed space standards local plans should not cover matters already addressed in building regulations. In addition, it is also notable that the latest consultation on the NPPF proposes to amend the Planning and Energy Act 2008 in relation to the setting of local energy efficiency standards that go beyond building regulations to make clear that local plans should not set higher energy efficiency standards for residential development. Once adopted the NPPF would also replace the 2023 Written Ministerial Statement (WMS) ‘Planning – Local Energy Efficiency Standards Update’. As such If PM13 remains both NZ2 and NZ3 would be inconsistent with national policy from the point at which the new NPPF is adopted with limited weight being given to these policies with decision making. In such a situation HBF would suggest that these policies are deleted.

However, at present the Planning and Energy Act 2008 and the WMS allow local planning authorities to set standards that are higher than building regulations, with the WMS noting that “Compared to varied local standards nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes” and that local standards can “add further costs to building new homes by adding complexity and undermining economies of scale”. After setting out these concerns, the 2023 WMS does go on to state that any standard that goes beyond building regulations should be rejected at examination unless the LPA does not have a well-reasoned and robustly costed rationale that ensures:
• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework.
• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).

HBF do not consider the approach set out in NZ1 to be consistent with the WMS nor that the implications of such a policy have been properly assessed in the supporting evidence base. Our detailed points are set out be-low.

The approach proposed by the Councils based on energy use is inconsistent with the approach set out in the WMS and as such is unsound. The intention of the WMS and the Planning and Energy Act was to enable lo-cal authorities to go beyond building regulations but not to set wholly new standards. This was noted in by Justice Lieven’s decision which referred to statement by the Minister at the time where the minister con-firmed that councils “can go further and faster than building regulations, but within the national framework” and that the intention was for “… local authorities, in setting energy efficiency standards, to choose only those standards that have been set out or referred to in regulations made by the Secretary of State, or which are set out or endorsed in national policies or guidance issued by the Secretary of State. That approach was taken with a view to avoiding the fragmentation of building standards, which could lead to different stand-ards applying in different areas of the country …”.

It should also be noted that the Government have considered as part of consultation on the Future Homes Standard whether it was appropriate to use a delivered energy metric such as the one being proposed in the policy position paper and have concluded that these do not offer any additional benefits to those being taken forward by Government. Therefore, if the Council are to require standards above those set out in building regulations they must be expressed as a percentage of the target emission rate and not as an energy use target in order to avoid fragmentation of the standards with different requirements being set in different areas which it must be recognised was not only an expectation of the WMS but also of the legislation that permits council to adopt higher standards in local plan in the first place. As such the HBF do not consider the council to be justified in departing from either the WMS or the Planning and Energy Act (2008).

With regard to viability, the Council’s Viability Assessment includes an uplift of £7,500 per unit to take ac-count of the Future Homes Standard with an additional 8% or 5% uplift to build costs depending on the size of the development. Both these uplift would mean the costs of delivering the proposed standards are not dis-similar to those in set out in the report ‘Ready for Zero’ that was published by the Future Homes Hub in 2023 . However, in addition to considering viability the Council will also need to provide evidence as to the potential impact on the affordability of new homes and the ability of the development industry to meet these standard when the plan is adopted.

With regard to deliverability of zero carbon homes HBF would not disagree that the proposed standards are technically feasible. However, HBF are concerned as to the impact these requirements will have on the rates at which sites can deliver new homes on all types of sites. Given that the standards proposed are higher than those proposed by Government in the Future Homes Standard and will require higher levels of fabric efficiency, which in turn will require new skills and materials that may not be readily available, HBF are concerned this could slow delivery in the short to medium term as supply chains are developed.

It has been recognised by the FHH that to deliver higher standards will require phased transitional arrangements to enable a steady build-up of skills and ensure quality. The FHH also notes in its report Ready for Ze-ro that even if a short transition period between current standards and those similar to the Councils are pro-posing that this would “… create a high risk of quality problems, inflated costs and, potentially, stalled build programmes.” However, HBF could find no evidence that the Council has considered whether its proposed standard will impact on the rate at which new homes can be built. The Council will need to speak directly to a range of housebuilders operating in Reading to understand the impact of its policy on the rate at which homes will be delivered on its allocated sites. Without any consideration of delivery then the Council’s decision to go beyond what is required by building regulations is clearly unjustified

While HBF understands the desire for LPAs to go further it must be recognised that current policy outlines that even where development can viably implement higher standards this must be within a consistent technical framework and approach to assessing building performance against those technical standards. Indeed, this has long been the case in planning policy with paragraph 159b of the NPPF stating that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards”.

If the Councils have the evidence to show that the policy is deliverable, they will need to ensure that all other policies in the local plan are consistent with delivering the levels of embodied carbon being proposed. The most energy efficient design will inevitably lead to less variety in the built form in order to reduce the surface area of the building. This will need to be reflected in design policies and any design codes that are produced to ensure that development is not refused for seeking to meet energy efficiency standards but, for example, not being designed in the character of the local area.

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

TWSL raises concerns that Policy NZ1’s requirement for residential development to generate 80kWh/m² per year of renewable energy is impractical, difficult to accurately calculate due to reliance on occupant energy use, and likely to significantly increase build costs, with potential impacts on housing affordability. Additional concerns relate to grid capacity constraints and the feasibility of providing photovoltaic panels across all housing types.

Please refer to Lichfields written representations letter obo Taylor Wimpey Strategic Land, dated 14 January 2026.

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

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

Please see attached document for the rest of our representations.

see attached

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

1 INTRODUCTION
Context
Gladman Developments Ltd. (Gladman) welcome the opportunity to comment on the
Colchester City Council Preferred Options as part of the Local Plan Full Update and
request to be updated on future consultations and the progress of the Local Plan.
Gladman specialise in the promotion of strategic land for residential development
and associated community infrastructure and have considerable experience in
contributing to the development plan preparation process having made
representations on numerous planning documents throughout the UK alongside
participating in many Examinations in Public.
This submission provides Gladman’s formal representations to the Regulation 18
consultation.
Gladman Developments have several land interests in Colchester City’s authoritative
area which are being promoted through the emerging Local Plan Update. The
following sites were submitted to the Call for Sites and are considered to be suitable
and sustainable locations for development:
• Land off Baker’s Lane, Braiswick (around 100 dwellings, policy reference PP7)
• North-East Colchester (west of Harwich Road, cumulating approximately 750
of the total 2,000 dwellings of the entire allocation PP9)
• Land off Colchester Road, West Mersea (up to 100 dwellings)
• Land off Rowhedge Road, Colchester (up to 75 dwellings)
The sites are available, suitable, and deliverable for housing as summarised in Section
6 of this representation, and two of these sites (at Baker’s Lane and at Harwich Road)
are draft allocations. Gladman looks forward to engaging further with the Council as
the plan progresses.
This submission also has been produced largely utilising the 2024 NPPF (National
Planning Policy Framework) regulations recognising that the Council are seeking to
submit their Local Plan before the December 2026 deadline. We note that a revised
NPPF consultation has very recently been announced (on 16th December 2025), and
therefore the council will need to carefully consider any potential implications for the
emerging Local Plan.
One minor house-keeping comment would be that draft local plans are often very
long documents, and so it is useful for the reader to have access to the whole
document as one, single, PDF file. Unfortunately, the draft plan is not available in this
format and we found it difficult to navigate the document via the website portal,
which requires scrolling through the web pages. A single file that can be downloaded
is therefore requested for future consultations.
2 LEGAL COMPLIANCE
Duty to Cooperate
The Duty to Co-operate, as a legal test, has now been rescinded by the Levelling Up
and Regeneration Act, which received Royal Assent on 26 October 2023. However,
engaging with prescribed bodies on relevant strategic and cross boundary matters
remains an important part of the plan making process.
The revised Framework introduced a number of significant changes to how local
planning authorities are expected to cooperate including the preparation of
Statement(s) of Common Ground (SoCG) which are required to demonstrate that a
plan is based on effective cooperation and has been based on agreements made by
neighbouring authorities where cross boundary strategic issues are likely to exist.
Planning guidance sets out that local planning authorities should produce, maintain,
and update one or more Statement(s) of Common Ground (SoCG), throughout the
plan making process.
. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for
strategic cross-boundary matters and will need to demonstrate the measures local
authorities have taken to ensure cross boundary matters have been considered and
what actions are required to ensure issues are proactively dealt with e.g. unmet
housing needs.
Sustainability Appraisal
In accordance with Section 19 of the 2004 Planning and Compulsory Purchase Act,
policies set out in Local Plans must be subject to Sustainability Appraisal (SA).
Incorporating the requirements of the Environmental Assessment of Plans and
Programmes Regulations 2004, SA is a systematic process that should be undertaken
at each stage of the Plan’s preparation, assessing the effects of the Local Plan’s
proposals on sustainable development when judged against reasonable alternatives.
The Council should ensure that the results of the SA process conducted through the
preparation of the Local Plan clearly justify the policy choice made, including
proposed site allocations (or decisions not to allocate sites) when considered against
reasonable alternatives. In meeting the development needs of the area, it should be
clear from the results of the assessment why some policy options have been
progressed and others have been rejected.
The SA must demonstrate that a comprehensive testing of options has been
undertaken and that it provides evidence and reasoning as to why any reasonable
alternatives have not been pursued. A failure to adequately give reasons in the SA
could lead to a challenge of the Council’s position through the examination process.
The SA should inform plan making. Whilst exercising planning judgement on the
results of the SA in the Local Plan is expected, the SA should still clearly assess any
reasonable alternatives and clearly articulate the results of any such assessment.

3 NATIONAL PLANNING GUIDANCE
National Planning Policy Framework
The National Planning Policy Framework (NPPF) sets out the Government’s planning
policies for England and how these should be applied within which plan-making and
decision-taking. The NPPF requires plans to set out a vision and a framework for
future development and seek to address the strategic priorities for the area. Local
Plans should be prepared in line with procedural and legal requirements and will be
assessed on whether they are considered ‘sound’.
The National Planning Policy Framework sets out four tests that must be met for Local
Plans to be considered sound. In this regard, we submit that in order to prepare a
sound plan it is fundamental that it is:
• Positively Prepared – The Plan should be prepared on a strategy which seeks
to meet objectively assessed development and infrastructure requirements
including unmet requirements from neighbouring authorities where it is
reasonable to do so and consistent with achieving sustainable development.
• Justified – the plan should be an appropriate strategy, when considered
against the reasonable alternatives, based on a proportionate evidence base.
• Effective – the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
• Consistent with National Policy – the plan should enable the delivery of
sustainable development in accordance with the policies in the Framework.
The NPPF reaffirms the Government’s commitment to ensuring up-to-date plans are
in place which provide a positive vision for the areas which they are responsible for,
to address housing, economic, social and environmental priorities and to help shape
the development of local communities for future generations.
To support the Government’s continued objective of significantly boosting the supply
of homes, it is important that the Colchester City Council Local Plan provides a sufficient amount and variety of land that can be brought forward, without delay, to
meet housing needs.
In determining the minimum number of homes needed, strategic plans should be
based upon a local housing needs assessment defined using the standard method,
unless there are exceptional circumstances to justify an alternative approach.
Once the minimum number of homes that are required is identified, the strategic
planning authority should have a clear understanding of the land available in their
area through the preparation of a strategic housing land availability assessment. In
this regard, paragraph 67 sets out specific guidance that local planning authorities
should take into account when identifying and meeting their housing needs. Annex
2 of the Framework (2024) defines the terms “deliverable” and “developable”.
Once a local planning authority has identified its housing needs, these needs should
be met as a minimum, unless any adverse impacts would significantly and
demonstrably outweigh the benefits of doing so. This includes considering the
application of policies such as those relating to Green Belt and giving consideration
as to whether or not these provide a strong reason for restricting the overall scale,
type and distribution of development (paragraph 11b)i.). Where it is found that full
delivery of housing needs cannot be achieved (owing to conflict with specific policies
of the NPPF), Local Authorities are required to engage with their neighbours to ensure
that identified housing needs can be met in full.
As outlined in our Introduction section, a revised NPPF was announced on 16th
December 2025. In light of this, the council will need to ensure that any future
consultations for this draft Local Plan are compliant with this revised version. In the
interim, this rep has been submitted largely in conjunction with the 2024 version of
the NPPF.
Planning Practice Guidance
The need to plan for the sufficient delivery of homes is affirmed in the Written
Ministerial Statement (WMS) given by the then Deputy Prime Minister, and Secretary of State for Housing, Communities and Local Government, Angela Rayner on 30 July
2024, in addition to the on-going consultation on proposed revisions to the
Framework and other changes to the planning system.
The WMS reaffirms that the country is in “the most acute housing crisis in living
memory” and is clear in its conclusion that “there is no time to waste. It is time to get
on with building 1.5 million homes”. These are now material considerations for plan
making and decision making and clearly set the tone and direction of the newly
elected Government.
4 REGULATION 18 CONSULTATION
Introduction
The sections that follow below include comments from Gladman on the overall
strategic approach taken by the council, as well as reviewing some of the proposed
policies and site allocations.
The minimum end date of the plan should be 15 years from adoption, as per
paragraph 22 of the Framework. At present, it is difficult to follow which year is the
starting point for the plan period – in the draft plan under para 2.14 it confirms the
plan period is 2025-2041, however in Section 14, Appendix A, Table 14.1 (when
confirming the new policies over the previous draft policies) it is stated that the plan
period is 2026-2041. The plan seemingly seeks to cover the period 2025 or 2026 to
2041, resulting in either 15 or 16 years being planned for. Clarity is sought on this
regarding the start date.
The most appropriate starting date of the two is 2026. The standard method is a
forward-looking assessment of need taking into account both under and oversupply
in its methodology and uses a base period that is required to start in from the year
that the housing need is calculated. In order to be consistent with national policy,
Gladman would recommend that the plan period to start in the most recent year in
which the housing need is calculated.

Additionally, our experience of Local Plan examinations suggests that delays to the
local plan-making process are inevitable, and so the plan period only going to 2041,
i.e. 15 or 16 years from the Regulation-18 consultation, is too short. It is advisable,
therefore, to look beyond 2041 to ensure that the required period is covered
regardless of any likely delays. It is suggested that the plan period be amended to at
least 2026-2043.
A Settlement Hierarchy for Colchester
Settlement Hierarchy
The settlement hierarchy is presented under draft policy ST3: Spatial Strategy, giving
5 separate tiers, as well as open countryside.
Gladman consider that the draft settlement hierarchy is appropriate for the growth
of the authoritative area for the plan period. The proportionate distribution of growth
is important to ensure that settlements – both large and small – remain sustainable
and that growth takes place in locations which can support it.
Gladman are promoting sites across the settlement hierarchy in Colchester (three
sites) as well as one in West Mersea, which has Large Settlement status in the draft
plan. These site promotions are suitable and sustainable locations due to the range
of services and facilities they provide, the sustainable public transport choices
available and quality of life they offer residents. New development in these locations
can contribute to the vitality and viability of local services, stimulate the local
economy through increased resident expenditure and support local education and
healthcare facilities through S106 and/or CIL contributions.
Housing Figures and Requirement and Growth Strategy
Draft policy ST5: Colchester’s Housing Need provides details of the housing numbers
required over the plan period, with the plan period here stated as being 2025-2041
(16 years). It confirms that at least 20,800 new homes are needed to meet the future
housing need, equating to 1,300 dwellings per year.

In determining the minimum number of homes needed, strategic plans should be
based upon a local housing needs assessment defined using the standard method,
unless there are exceptional circumstances to justify an alternative approach.
We note in draft policy ST5 that provision will be made for at least 20,800 new homes
across a range of tenures. These are broken down by: existing commitments, Tendring
Colchester Borders Garden Community, windfall and the local plan allocations. These
four give a combined estimated total of 21,106 dwellings.
These figures allow for a 308-dwelling buffer from the housing need, equating to a
1.48% buffer on what is needed over the 16-year period. This figure is far too low to
be sustainable and relies too heavily on all of the allocations coming forward with the
estimated dwellings numbers, as well as appropriate windfall levels being available. It
is advisable that this buffer is increased to provide more confidence that the housing
need is met.
In light of this, it is suggested that more sites should be identified in order to ensure
that the need of 20,800 is not met. The most appropriate way to approach this would
be to include a greater number of short-medium sized sites, as these not only assist
with the overall housing need but also greatly assist with delivery in the first few years
of a local plan.
Gladman is promoting such sites in West Mersea, which can accommodate around
100 dwellings, and off Rowhedge Road, Colchester, which can accommodate around
75 dwellings. Further detail on this can be found in Section 6: Site Submissions below.
Further, the need for affordable homes is a pressing issue, and the Council may wish
to pursue a higher housing requirement to maximise the delivery of affordable
homes. This approach has been progressed by East Riding of Yorkshire.
Draft Policy ST3 sets out the strategy for growth across the authority area. The
planned growth within the draft plan is concentrated in existing settlements in a
proportional manner to ensure that there are sustainable levels of growth in
appropriate locations (i.e. utilising the settlement hierarchy).
In principle, Gladman consider such an approach to be suitable, however, there are
elements of this which require review.
Whilst we agree with this proportionate approach, the numbers which add up to meet
the housing need across the plan period are so fine that it would appear that there
are several sites that the plan is lacking to ensure that the housing need is met. To
continue with the proportionate approach using the settlement hierarchy, we would
recommend that more small-medium sized sites are allocated across the settlements.
As advised, such sites assist with both the overall housing need and also greatly assist
with delivery in the first few years of a local plan. Having more planned development
will also take the pressure off the dependence for windfall development to come
forward. The windfall reliance accounts for around 10% of the housing need, which
in our experience in Examinations is not wholly supported by the Planning
Inspectorate. It is therefore advisable to allocate more sites to reduce the windfall
dependency.
In the first instance, we submit that such sites should come forward in the larger
settlements, such as Colchester and the Large Settlements, and that Gladman’s land
interests at Baker’s Lane, West Mersea and off Rowhedge Road, Colchester would be
ideally positioned to fulfil this role.
The Rowhedge Road site lies adjacent to the Colchester Urban Area, is sustainably
located in relation to the city’s services and amenities and further development in the
location can be successfully assimilated into the existing settlement and its
surroundings. In addition to its status as a Large Settlement, West Mersea is the only
designated Large Settlement in the hierarchy for some distance geographically, such
that growth here will help support the wider area as a growth hub, which helps
support the Small Settlements of East Mersea, Peldon, Great Wigborough and Salcott.
Further information on our sites in West Mersea and land off Rowhedge Road can be
found in Section 6 below.
Finally, whilst not strictly concerned with housing numbers and growth, Policy ST2:
Environment and Green Network Sites sits alongside the Local Plan’s other suite of proposed Strategic Policies, and seeks to identify “Strategic Areas that present the best
opportunities for habitat creation and enhancement aimed at improving biodiversity”,
which it states are shown on the policies maps as ‘strategic biodiversity areas’. The
policy goes on describe how these areas will be protected, with support given to
strengthening and enhancing connections between habitats to improve the
contribution to the biodiversity network.
As outlined above, Gladman submit that there may be a requirement to identify
additional sites to ensure Colchester’s housing needs are met. At this stage, we
therefore suggest that there may be a corresponding need to review any policies that
may be relevant to achieving this objective, which could include Policy ST2.
In this regard, we question whether the ‘protection’ of ‘strategic biodiversity areas’ is
appropriate (if this is what the policy is proposing), and query whether the Local Plan
should be taking a more balanced approach, which could recognise that development
proposals can often provide the opportunity to secure the long-term management
of green infrastructure. Gladman reserve the right to comment on this policy and any
supporting evidence base documents in response to future consultations.
Development Management Policies
Draft Policy GN5 – Suitable Alternative Natural Greenspace
We generally agree with the principle of this policy, however Blackwater Estuaries
Special Protection Area is the main reason for our site in West Mersea not being
allocated for residential development. Given that there are mitigation measures
available under draft policy GN5, it is unclear why the site has been ruled out so
hastily.
Draft Policy LC3 – Coastal Areas
Policy LC3 seeks to take forward Colchester’s Coastal Protection Belt designation, as
presently covered by adopted Section 2 Local Plan Policy EN2. The policy advises that
in such areas of the borough an integrated approach to coastal management will be
promoted and development will only be supported if it meets certain criteria.
As detailed in Section 6 of these submissions below, Gladman are currently promoting
Land off Rowhedge Road, Colchester, which is situated within the Coastal Protection
Belt as defined on the Council’s draft Policies Map. The supporting text to Policy LC3
advises that its purpose “is to protect Colchester’s rural and undeveloped coastline from
inappropriate development that would adversely affect its rural, undeveloped and open
character…“. However, we question whether circumstances of the Rowhedge Road
site are consistent with these characteristics.
The Rowhedge Road site lies adjacent to the existing Colchester urban area, with
existing areas of development adjoining the site the south east and west, and existing
areas of woodland planting bordering the site to the north and east. Any
development in this location would be experienced as part of the existing built-up
area, would be well contained from its wider context, including the Colne Estuary, and
would be accompanied by a comprehensive framework of green infrastructure and
landscaping.
We therefore query how development in this location could adversely affect the rural,
undeveloped and open character of Colchester’s coastline, and how including the
Rowhedge Road site within the Coastal Protection Belt designation is consistent with
these aims. We would request that the inclusion of the Rowhedge Road site within
the Coastal Protection Belt designation is reviewed.
As detailed in Section 6 of these submissions, we submit that Land off Rowhedge
Road is well positioned to accommodate further residential development to meet
Colchester’s needs, and that it could do so successfully without adversely affecting to
the site’s setting and surroundings.
Draft Policy NZ1 – Net Zero Carbon Development (in operation)
We disagree with the need for this policy. Whilst we acknowledge the importance of
new dwellings being environmentally sustainable for future generations, such
requirements will be made under national policy, thus making a development
management policy on this aspect unnecessary. We would therefore request that this
policy be removed and left for the national building regulations to accommodate.

However, should this policy remain, we would request that instead of all dwellings,
that a percentage of dwellings per site be built out to the standards requested. This
would result in net-zero carbon dwellings still being built out, but without the
detriment of unaffordability for those seeking to buy, as ultimately the additional
costs incurred in making dwellings net-zero will be reflected in the house prices and
therefore the fall upon purchaser.
Draft Policy H6 – Self and Custom Build
We support this policy. Requesting 2% of large developments to be self/custom build
plots is appropriate, as this is a reasonable number and does not negatively impact
smaller schemes with mandatory self/custom build requirements, as the requirement
is only for schemes of 150+ dwellings. This is provided that the evidence supports
these figures.
We also agree with the 12-month turnaround time on the Self-Build Register, with
sales on the open market taking place after this period should the plot(s) not be
purchased.
5 SITE ALLOCATIONS
General Approach and Housing Trajectory
As above, the 20,800 dwellings required over the plan period are expected to come
forward in four possible ways: existing commitments, Tendring Colchester Borders
Garden Community, windfall and the local plan allocations.
Gladman agrees with the proportionate approach and agrees with the residential
allocations that have been included.
However, as outlined above, there is very little room for error in terms of housing
numbers (308 across the entire plan period). Given this tight margin, it would be
appropriate to seek further small to medium sized sites for allocation to assist with
these margins, as well as assure a 5-year housing land supply (as such sites tend to
come through in the early years of a local plan).

As advised, Gladman are promoting sites in West Mersea and Rowhedge Road which
are wholly appropriate to assist in this regard. Further details are in Section 6: Site
Submissions below.
6 SITE SUBMISSIONS
Land off Baker’s Lane, Braiswick
Land off Baker’s Lane is a highly sustainable location for growth in the draft local plan
and lies within the proposed settlement boundary for Colchester. This allocation
(reference PP7) is around 18.5 acres and can provide around 100 dwellings. Gladman
strongly support the inclusion of this site in the plan, and it is available, deliverable
and achievable to bring a positive level of residential development to the settlement.
The site lies in a natural direction of growth to the west of the settlement, with recent
development taking place to the east of the site. The site also lies within reasonable
walking distance of Colchester Train Station, as well as the nearby primary school and
nursey. Additionally, there are two public rights of way (PROWs) joining the site on
its western boundary, again emphasising the site’s strong pedestrian linkages to its
surrounding areas.
Gladman are seeking expert advice for pedestrian connections to the existing footway
on Baker’s Lane. We are also open to the possibility of a safe and appropriate
pedestrian crossing if required.
An appropriate buffer will be provided on any application for the Moat Farm Dyke
scheduled monument to the east of the site. We are currently liaising with experts on
this matter to ensure the best possible outcome for this aspect.
Highways access can easily be obtained along the western boundary of the site, with,
given the limited space along Baker’s Lane, pedestrian footpaths being available
within the site’s boundary as part of a future scheme.

A policy-compliant level of affordable housing will be provided, in a range of sizes
and tenures. The site will accommodate a range of house types and sizes informed
by local need.
The site acts as a crucial gatekeeper for future growth of Colchester in a westerly
direction, with possibilities to the south and west of this site becoming available after
development here at Baker’s Lane. Development of this site is therefore crucial for
any future growth of the settlement in a westerly direction.
North-East Colchester
As aforementioned, Gladman are promoting a 97-hectare site at North East
Colchester (west of Harwich Road) for a residential led development comprising
approximately 750 homes, a local centre, a two form entry primary school and
strategic green space. This site forms part of a larger site allocated for around 2,000
homes under draft Policy PP9. In accordance with the requirements of draft Policy
PP9, Gladman have worked alongside other land promoters and developers who own
or control land within the remit of Policy PP9 and have prepared a Masterplan
Framework jointly with Gleeson, but with input from other parties with smaller land
holdings, including Taylor Wimpey and Mrs Julie Clinch. The Draft Masterplan
Framework (‘the Framework’) can be found at Appendix 1, appended to this
submission’s email.
The purpose of the Framework is to articulate a vision for the future development of
North East Colchester. It seeks to set out shared objectives, spatial principles and
development aspirations that could guide the successful delivery of the site, aligning
with the requirements of national and local planning policy, including the
expectations of emerging Policy PP9. Following this Regulation 18 consultation,
further engagement with Colchester City Council and other key stakeholders will be
undertaken with regards to the content of the Framework.
The Framework is underpinned by a series of technical studies undertaken on
Gladman and Gleeson’s sites, forming a clear and strong evidence base to the proposals. Together these assessments have informed a constraints and
opportunities mapping exercise, which has assisted with preparing a deliverable
Masterplan that could accommodate the requirements and expectations of the draft
Policy PP9. This includes the expectation that the allocation would provide land for a
new primary school and a local centre. As discussed below, it is considered that the
Harwich Road site would be the optimum location to accommodate these facilities.
Gladman is supportive of the allocation of land west of Harwich Road as part of the
North East Colchester allocation. The Framework has been prepared jointly with
Gleeson to demonstrate that the site can viably deliver all of the requirements set out
by the policy. Each of these requirements in so far as that they relate to the Gladman
site are discussed in further detail below.
Land Uses and Infrastructure Provision
Draft Policy PP9 anticipates the delivery of approximately 2,000 new dwellings of a
mix and type of housing to meet evidenced needs which is compatible with
surrounding development. Applying a range of locally appropriate densities across
the Gladman site, around 750 dwellings could be delivered which would include 1-5
bedroomed homes in a range of house types.
As demonstrated by the Framework, the Gladman site will deliver a number of
additional services and facilities that will be available for new and existing residents.
A 1-hectare Local Centre will be delivered on-site, providing small scale retail and
community uses and offering economic and social benefits. A 2.1-hectare site for a
new two form entry primary school is also proposed by the Framework on the site,
increasing the offer of education facilities within the locality in accordance with the
emerging policy and the proposed requirements of the Local Education Authority.
The decision has been made to accommodate all community uses (local centre,
school and strategic open space) required by draft Policy PP9 on the Gladman
controlled site to the west of Harwich Road, as the physical attributes of the site, as
well as opportunities for safe and suitable access are most favourable compared with
other land parcels within the allocation. The proposed location within the centre of the Gladman site will ensure that the community uses and the proposed school can
benefit from strong frontage and visibility along the primary route from Harwich
Road. Gladman are therefore able to provide certainty around the delivery of this
necessary public infrastructure, as these uses will be proposed as part of a future
outline application submitted by Gladman, should the site be allocated within the
Local Plan.
Highways and Access
The Site is sustainably located in respect of access to facilities and services, including
public transport, with methods of travelling other than private car a viable option for
future occupiers. Furthermore, public transport connections could also be available
from within the site with the primary access route running through the development,
which will be of the necessary standard to accommodate a bus route connecting St
John’s Road to Harwich Road.
Draft Policy PP9 notes a requirement for safe and suitable site access to required
highway design standards. With regards to the Gladman site, the Framework propose
two primary access points off Harwich Road and one primary access point off St Johns
Road. Initial feasibility studies confirm that safe and suitable access can be provided
in these locations, supported by the introduction of traffic-calming measures to
Harwich Road to improve walkability and a creation of a new safe crossing at the
intersection with the active travel corridor.
In response to the requirement for the provision of active and sustainable travel and
ensuring connectivity with existing Public Rights of Way the Framework will deliver
an enhanced pedestrian and cycle network. As well as a primary active travel corridor
linking the Gladman site to the wider PP9 allocation. the Framework also illustrates
the provision of a secondary active‑travel route within the Gladman site, connecting
Bullace Close, Dunthorne Road and Harwich Road. These key networks will be
supported by a wider network of formal and informal footpaths that link the local
centre with dwellings within the site and surrounding communities.

Account has also been taken of land within the allocation to the north of the Gladman
site, which would require access to be taken through the Gladman site. The
Framework allows for vehicular and pedestrian access into this parcel to ensure
comprehensive development across the two sites.
Green and Blue Infrastructure Provision
Enhanced open space in excess of 10% of the total allocation area is required by draft
Policy PP9, including one area of ‘strategic’ open space, and multiple areas of
incidental open space. It is proposed that approximately 40% (38.12 hectares) of the
total PP9 allocation will be retained as green space, supplemented by additional POS
within development parcels.
The green and blue infrastructure strategy set out by the Framework brings together
existing woodland, hedgerows, trees, with new play spaces, amenity areas,
community growing spaces, SuDS features, natural and semi‑natural habitats, and a
connected path network. Their design and placement have been informed by
technical inputs and the ambition to create an integrated network that supports both
residents and biodiversity.
As demonstrated by the Framework, the Gladman site will accommodate an area of
strategic open space in the form of a new local park centred around an existing
mature oak tree which will act as a focal point for the new and existing residents. It
was agreed with all participating parties of the framework that the Gladman site was
the most appropriate location within the allocation for this community space due to
its flat topography, accessibility from existing surrounding communities (which will
be further enhanced) and the opportunity to create a community hub combined with
the local centre and school sites.
In response to the requirements of draft Policy PP9, an appropriate surface water
management strategy can be delivered. The Framework Plan identifies the indicative
location of Sustainable Drainage Systems (SuDS) to attenuate surface water, which in
relation to the Gladman site are indicatively located along the northern site boundary
following the advice of Gladman’s flood risk and drainage consultant. To support this, an initial Flood Risk Assessment (FRA) has been undertaken to evaluate potential
flood risks associated with the proposed development and to recommend suitable
mitigation measures, where necessary, to reduce flood risk to an acceptable level.
Protecting and enhancing Landscape Features
Draft Policy PP9 refers to a number of site-specific features which should be protected
and enhanced as part of future development proposals. Of particular relevance to the
Gladman site is the Bullock Wood SSI, is a designated ancient woodland which should
be appropriately buffered from development. The Framework demonstrates that
development will offset from Bullock Wood, allowing for a 15m wide corridor with
walking routes and incidental play, and a soft, informal green residential edge to the
ancient woodland. At the outline application stage, Gladman will seek to secure the
protection of the Ancient Woodland and retention of mature trees and hedgerows
within the site.
Summary
Gladman welcome the inclusion of the land at North East Colchester as a proposed
strategic allocation and hope the additional information provided within this
representation and enclosed Framework assists the Council in demonstrating that this
site is deliverable and suitable for an allocation in the Regulation 19 plan. The
Gladman site is wholly deliverable and can meet the site-specific requirements of
draft Policy PP9.
Land off Colchester Road, West Mersea
West Mersea is designated as a Large Settlement in the draft settlement hierarchy
(Policy ST3). With an estimated population of over 7,000, it is a highly sustainable
location for growth. Gladman are promoting land off Colchester Road for residential
development.
Land off Colchester Road (ref: 10748) is capable of delivering around 100 homes and
relevant community infrastructure. The entire site is approximately 12.5 acres, and it lies on the main access road into the settlement from the north. Colchester lies
around 5 miles from West Mersea, and given the site’s location the impact on the
roads in West Mersea will be minimal as most would head immediately north towards
the city.
The site comprises arable fields and 3 residential properties lying immediately to the
north-east of the site, with a fourth slightly further north, all on Paeony Chase. The
eastern and southern sides of the site run parallel with Colchester Road, with some
dwellings immediately to the site’s west and fields to the north-west. The site’s
location can be found in Figure 1 below. It is relatively flat in nature and has no flood
risk.
A policy-compliant level of affordable housing could be provided, in a range of sizes
and tenures. The site will accommodate a range of house types and sizes informed
by local need.
Suitable mitigation and precautionary measures will be implemented on site to
ensure that there are no significant adverse effects on ecology and 10% biodiversity
net gain can be achieved through new habitat creation and enhancement.
The negative impacts the site has been labelled with in the Sustainability Appraisal
are the impacts on Historic Environment and Landscape, with the latter presumably related to impacts on the estuary. However, whilst we acknowledge the importance
of such an environmental feature, this should not be a reason preventing this site for
allocation. In terms of proximity, the site lies several fields away from the estuary itself,
and there is already existing built form between the site and the estuary. The
aforementioned Paeony Chase consists of four dwellings, all of which lie closer to the
estuary than the site. There is therefore no additional encroachment to the estuary,
as the built form already exists – this site simply seeks to build up to the existing
dwellings.
Additionally, mitigations can easily be implemented on this site – its orthodox shape
allows for open space to be enjoyed to the north-west corner, thus maintaining a
buffer between any houses on this site to the estuary, whilst simultaneously allowing
for new and existing residents to enjoy the view of the estuary. Contrary to the site
assessments, residential development of this site can have a positive impact on the
estuary and given its location in the wider scheme of the settlement, its size and how
the settlement itself functions, makes it an ideal location for a sustainable residential
scheme.
There is one listed building near the site, which is the sole property on the northern
side of Paeony Chase. There is already built form between this building and the site,
meaning any visual impacts on the listed building from developing the site would be
minimal. Further, mitigation measures can be undertaken to minimise the any
potential impacts on the listed building.
Gladman have explored several assumptions concluded by the LPA pertaining to
residential land interests in the authoritative area. Fundamentally, Gladman do not
consider that the site at West Mersea should be discounted primarily due to potential
impacts made upon the estuary, and can provide the Council with information
regarding our design approaches to mitigate this harm. In the context of a significant
national housing crisis and a significant rise in market and affordable housing needs
in the District, Gladman do not consider it appropriate nor justified to discount the
site on the edge of a highly sustainable settlement without due consideration of how the site could be delivered through landscape-led design. We would welcome the
opportunity to discuss this site further, and the significant benefits it can deliver with
the Council.
Land off Rowhedge Road, Colchester
As discussed in our submissions above, Gladman are currently promoting Land off
Rowhedge Road, Colchester for residential development. The site extends to a total
area of 3.99ha, with the site’s location and the extent of the land under promotion by
Gladman shown in Figure 2 below.
Figure 2 Land off Rowhedge Road, Colchester - Location Plan
Located immediately adjacent to the Urban Area of Colchester, which forms the top
tier of the Council’s settlement hierarchy and the main focus for development within
the borough area, Gladman submit that Land off Rowhedge Road is ideally situated
to deliver residential growth to meet Colchester’s housing
Land off Rowhedge Road is not subject to any technical, landownership or viability
constraints that would preclude its development and delivery. This is further evidenced by the suite of technical assessments that have been prepared in support
of Gladman’s current planning application for the site (Colchester City Council ref:
251150) which is currently pending determination with the authority.
The remainder of this section describes the site’s suitability for development, taking
account of the technical studies that have been undertaken to inform its delivery to
date, and describes how it would represent a logical location for further sustainable
development.
New Homes
The site could accommodate up to 75 dwellings, delivering a range of market and
affordable homes to meet the borough’s housing needs. In accordance with the
Council’s emerging policy position, 30% of the homes would be delivered as
affordable housing. The proposals can be delivered at a density that makes efficient
use of the land whilst also being appropriate for the location and respecting its
character and surroundings.
Transport and Accessibility
Vehicular access to the site can be achieved from Rowhedge Road and will ensure
that both pedestrians and cyclists can access the site. Traffic surveys undertaken in
support of Gladman’s current application submission have shown that this access
could suitably accommodate the number of vehicle movements associated with the
proposals, whilst also demonstrating that the site’s development would not have an
unacceptable impact on the operation of the wider highway network or on highway
safety more broadly.
A good range of services and facilities can be accessed from the application site by
walking and cycling. The proposals lie in close proximity to the range of amenities
present within Old Heath, whilst also benefitting from access to the greater range of
facilities that are available in the wider Colchester urban area. The nearest bus stops
to the site are situated on Rowhedge Road with further bus stops located on
Fingringhoe Road. These stops are served by a regular service to Colchester city centre and also provide access to the wider bus network, as well as Colchester railway
station.
Ecology
The development of the Rowhedge Road site would not cause harm to any ecological
designations or protected species that cannot be addressed through appropriate
mitigation and enhancement measures. A comprehensive suite of ecology surveys
have the assessed the site’s potential to provide habitat for bats, badgers, dormice,
reptiles, riparian mammals and great crested newts; through the implementation of
precautionary working measures, habitat enhancement and accepted mitigation
methods, it has been concluded that no unacceptable impacts will arise in this
respect.
The proposed landscaping scheme for the proposals will help to improve the site’s
habitat structure and diversity. This could include new scrub planting, the retention
and enhancement of existing on-site hedgerows and woodland planting, and the
sowing of an appropriate grassland mix. Enhanced and created habitats will be
positively and appropriately managed to maximise their biodiversity value and the
contribution they can make to ecological networks. Biodiversity net gains would be
secured in accordance with national policy requirements.
Landscape
Gladman’s current application submission has been supported by the preparation of
a Landscape and Visual Impact Assessment (LVIA). This describes how the site could
accommodate residential development without giving rise to any unacceptable
landscape and visual effects, whilst also concluded that it does not constitute or form
part of a ‘valued landscape’.
Submissions on the Rowhedge Road site’s identification as part of the Coastal
Protection Belt are provided in response to Policy LC3 in Section 4 of these
representations above. In this regard, it is questioned whether the inclusion whether
the coverage of the Rowhedge Road site by this designation is appropriately justified.
It is understood that the purpose of the Coastal Protection Belt is protect the
borough’s coastline from development that would adversely affect its rural,
undeveloped and open character. However, it is questioned whether the Rowhedge
Road site exhibits these characteristics. Development on the site would be
experienced as part of an existing, built-up developed area, would be accompanied
by a comprehensive framework of green infrastructure and landscaping, and would
be well contained from its wider context, including the Colne Estuary.
Historic Environment
Gladman’s current application submission has been supported by a Heritage Desk
Based Assessment (HDBA), describing how the development of the Rowhedge Road
site would not affect the setting or significance of any listed buildings or locally listed
buildings due to the absence of any historical functional associations and invisibility.
The HDBA also concludes that any archaeological interest in the site could be
addressed via archaeological recording, if this is deemed necessary.
Flooding and Drainage
A comprehensive Flood Risk Assessment (FRA) has also been prepared in support of
Gladman’s current planning application. This identifies how the site could be safely
developed in relation to the risk of flooding. Any development would be situated
within Flood Zone 1, with no built development or other vulnerable uses at risk of
flooding from any other source.
A suitable drainage strategy delivered in accordance with Sustainable Urban Drainage
System (SuDS) principles would be provided, and would ensure the development of
the site would not give rise to an increased risk of flooding on-site or elsewhere. This
drainage strategy would also include a three-stage treatment train to ensure there
are no impacts on the receiving watercourse in relation to pollutants.
Infrastructure Provision
It is not anticipated that the proposals will give rise to any infrastructure deficiencies
that cannot be appropriately and adequately addressed. In this context. Gladman would be willing to enter into a Section 106 agreement with Colchester City and Essex
County Council to secure proportionate upgrades to infrastructure where these are
shown to be necessary to accommodate any development proposals.
Summary
As can be seen from the above summary, it can be satisfactorily demonstrated that
there are no infrastructure or technical constraints that would prevent the delivery of
a sustainable and acceptable residential development at Land off Rowhedge Road,
Colchester.
Gladman and the site’s owners would welcome the opportunity to work with the
authority’s officers to bring a suitable proposal for the site forward, and submit that
it would represent a suitable and sustainable location for further resident
development as part of the Council’s emerging Local Plan proposals.
7 CONCLUSIONS
Summary
Gladman have provided comments on a number of the issues that have been
identified in the Council’s consultation material and recommend that the matters
raised are carefully explored during the process of undertaking the new Local Plan.
Gladman are generally in support of the plan as drafted, with some key caveats
highlighted above in both the Development Management Policies section, as well as
sites not included for allocation.
The sites that have been selected as draft allocations are good options. Those which
Gladman are involved in at Baker’s Lane and North East Colchester are sustainable
sites that will strongly assist in meeting Colchester’s housing need. However, there is
a need to extend the plan period further to reduce the risk of it being too short (i.e.
under 15 years) and no longer being legally compliant.
Further, to extend by a few years requires more sites to be allocated to support the
extra years, which would help to increase the resilience of the Local Plan and the buffer between the planned supply of housing vs. identified needs. Gladman
proposes further small to medium sites to assist with this need, and these can be
captured in the first few years of the plan period, which can also assist greatly with
the 5-year housing land supply.
Gladman also request that a housing trajectory be published as soon as possible to
ensure appropriate levels of growth take place throughout the plan period.
We hope you have found these representations informative and useful towards the
preparation of the Colchester City Council Local Plan.
Gladman welcome any future engagement with the Council and if you would like to
discuss this representations or other matters, please contact us at
policy@gladman.co.uk.

see attached

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

We have attached our detailed response for the site.

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

SEE ATTACHED

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.