as previous

These quotas need to be higher.

Comments as follows:
1. Positive to see the Roman River Corridor inclusion, and to see the high value Colne Valley landscapes recognised in the Landscape Character Assessment.
2. Positive to see mobility hubs and increased attempts at providing for sustainable transport.
3. Concern that the Brownfield Land Register remains very limited and focuses almost entirely on the urban area of Colchester. More should be done to proactively identify brownfield sites across the entire city boundary.
4. Concern that affordable housing delivery has only been 16% per annum on average for the past eight years and that the viability appraisals that accompany this plan must be rigrously tested to ensure that they are robust.
5. Concern that the strategy for Eight Ash Green results in car-dependent ribbon development along the 1124. Site PP32 should not be allocated. It represents unacceptable encroachment into the countryside.
6. Further concern that PP32 conflicts with the previous and latest Colchester Landscape Character Assesssments which seek to protect the Colne Valley. The site will be highly visible from Fordham and Chappel and cannot be screened. See attached by way of example. PP32 should not be allocated.
7. Allocation of Marks Tey North. All housing should be concentrated to the south of the site, in a high density development. Much of the Roman River must be kept inaccessible from residents and their dogs to ensure nature can flourish in the Nature Recovery area. The development must be safely connected to Marks Tey station by pedestrian and bike paths that do not use the polluted A120.
8. There should be minimum density requirements for all sites, not just urban ones.
9. The policy wording for conversions should change from 'only supported' to 'strongly supported.
10. There would be a policy to strongly support the bringing back of empty homes into use. An additional SA Monitoring indicator is required for number of homes brought back into use.

Affordable housing provision should be for local people not those from London areas.

West Bergholt Parish Council supports this policy.
The results of current ‘Housing Needs Surveys’ should carry some weight within this policy, as evidenced see attached West Bergholt’s Housing Needs Survey, November 2025, pages 2 and 3, and Affordability and Local Market Context Page 15

Alms Houses for local people on the housing list should be provided if any new development takes place.

Any housing development under the plan should include requirement for housing to rent. Affordability is not a measure in today’s environment. For instance “affordable housing” that starts with a price tag go north of £400,000 is risible.

Whilst the ICB understands that affordable rented housing should be prioritised, we think identifying NHS and emergency services staff (both clinical and administrative) staff as key workers and the need for key worker housing should also be included. Key worker housing is a very important part of staff retention in and around NHS properties and recognising this is something the ICB would like to work with CCC on.

I don't understand the percentage target for Affordable Housing. The LHNA implies 73% needed (941 out of 1290), but your target is 30% (8.13). I'm clearly missing something here, although it's hard to see a developer being happy at even 30%.

Mersea island cannot support any further building, we have no doctors, dentist, secondary schools, regular bus or any trains. Sewage is struggling, omotting directly onto oysterbeds. Water pressure is dropping significantly. Environmental and health disaster waiting to happen. In fact, what we do have is flooded roads, pot holes, coastal erosion and an array of rare birds, red squirrels insects and snakes. This island has many documentarys regarding its unique wildlife, bird migration. Mersea island is water stressed and expected to get worse due to climate change, population growth and the need to restore, protect and enhance the natural environment. Mersea is a high flood risk from the sea and rivers and only one small road off the island. In addition to this, Essex water quality is below the national average as a result of storm overflows discharging sewage into the water supply; pollution from fertilisers and traffic Do not ignore what you are destroying. The stroid cuts us off, we have thousands more living in caravans most of the year who are not registered.

Stanfords Colchester LLP has submitted detailed representations on this draft policy; please refer to the attached document.

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.

We object to Policy H2 as drafted. The policy is insufficiently clear, overly prescriptive, and risks undermining housing delivery. See attachment.

We note the policy sets out in relation to affordable housing:

“Proposals should be designed tenure blind, demonstrating no distinctly different design characteristics between affordable and market homes. To promote social cohesion, affordable housing provision should not dominate an area, road or building across the development.”.

We support that houses should be designed tenure blind although it is considered the wording “…affordable housing provision should not dominate an area, road or building across the development.” is undefined and subjective.

In the NPPF 2024 developments are sought to promote the creation of mixed and balanced communities with affordable housing integrated. Therefore, it is recommended the wording is changed to set out:

“Proposals should be designed tenure blind, demonstrating no distinctly different design characteristics and affordable homes. To promote mixed and balanced communities affordable housing should be well integrated through developments, with layouts and design that promote this, unless justified by site specific circumstances.”

We generally support Policy H2. It is important that policies allow for flexibility in tenure for older persons’ schemes and do not prescribe proportions of social rent, affordable rent or shared ownership homes, particularly on 100% affordable and flatted developments.

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.

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

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

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.

NHSPS support the principle of delivering affordable housing in order to meet identified local needs.
To further support this policy, we suggest the Council consider the need for affordable housing for
NHS staff and those employed by other health and care providers in the local authority area. The
sustainability of the NHS is largely dependent on the recruitment and retention of its workforce. Most
NHS staff need to be anchored at a specific workplace or within a specific geography to carry out
their role. When staff cannot afford to rent or purchase suitable accommodation within reasonable
proximity to their workplace, this has an impact on the ability of the NHS to recruit and retain staff.
Housing affordability and availability can play a significant role in determining people’s choices about
where they work, and even the career paths they choose to follow. As the population grows in areas
of new housing development, additional health services are required, meaning the NHS must grow
its workforce to adequately serve population growth. Ensuring that NHS staff have access to suitable
housing at an affordable price within reasonable commuting distance of the communities they serve
is an important factor in supporting the delivery of high-quality local healthcare services. We
recommend that the Council:
• Engage with local NHS partners such as the local Integrated Care Board (ICB), NHS Trusts
and other relevant Integrated Care System (ICS) partners.
• Ensure that the local need for affordable housing for NHS staff is factored into housing needs
assessments, and any other relevant evidence base studies that inform the local plan (for
example employment or other economic policies).
• Consider site selection and site allocation policies in relation to any identified need for
affordable housing for NHS staff, particularly where sites are near large healthcare
employers