Demolition permitted for replacement with authentic TA Designs befitting of the ancient City of Colchester

There will be no medical facilities for owners of new properties as the Island surgery closed its list for new patients in summer 2024. Sadly, despite much discussion about building a new, much larger surgery nothing has been decided and will not be acted upon in the near future.

The Island’s utility infrastructure is already strained and cannot service any more new developments.

Braiswick Residents Association objects to Policies CS1–CS4 because they do not adequately demonstrate how education, healthcare, and community facilities will be delivered in line with planned growth. Existing services are already under pressure, and the policies rely on future provision without firm commitments. This risks worsening access to essential services and undermines the creation of sustainable, balanced

Retaining the existing Copford Village Hall currently shown in PP29, may be an option as it is both viable and well used by the local community, plus the land it is on is registered to the Charity Commission.
If the proposed development cannot take place without this land then there is a discussion needed with the existing Trustees of the Village Hall and the Charity Commission about what-if any-circumstances might see this site becoming available.

The Community in Marks Tey is divided by the roads - the A120 and the A12. There is no longer a local pub. people do not walk along the A120.

West Bergholt Parish Council supports this policy.

P126

The requirements of draft Policy CS1 in relation to the ‘loss’ of community facilities would be contrary to the NPPF, which states that planning policies and decisions need to take account of local strategy to improve health and well-being for all sections of the community (paragraph 98).
The policy requirements may not align with the health strategies for future healthcare provision, which needs to be predicated on achieving the best possible health outcomes for the population while providing a cost-effective and efficient service. Restricting provision to certain locations and requiring the proposed level of marketing evidence could jeopardise delivery of this strategy and, therefore, flexibility needs to be built into the policy wording to ensure that it represents an appropriate strategy for securing sustainable development.

In light of the above, it is requested that requirement (a) of Policy CS1 is amended to read “An alternative equivalent facility to meet local needs and serve existing and future communities is, or will be, provided. in an equally or more accessible location within a minimum walking distance of the locality (800m or the minimum distance based on that appropriate for the facility being provided as set out in the relevant evidence);”

Centralised EV charging locations for buses, local authority, health, social and emergency vehicles to maximise usage of the charging resources.
Ensure sufficient electrical power to health sites as part of the move to Carbon Net Zero.

The Campaign for Pubs supports the inclusion of Policy CS1 as it offers protection to public houses and that these are identified as valuable community facilities. This protection could be strengthened if the following measures are added.

1. To “evidence of marketing requirements” - expand that ‘realistic market value’ for a public house means that the pub has been valued as a public house and not as a private house or development site (justification - the value of a private house or development site is usually higher that that of a public house and could discourage potential purchasers from taking on the premises as a business).

2. Viability - applications for Change of Use of a public house should be accompanied by a report undertaken by an independent Chartered Surveyor, to demonstrate that the pub is unable to trade viably. The Campaign for Pubs can provide independent guidance to assist with assessment of the validity of this report, if required.

3. In Justification, we would encourage, as other councils have done (e.g. Norwich City Council), that public houses protected by Policy CS1 are listed as an appendix. The listing could be headed as follows:
“The following public houses are subject to protection under policy CS1. Pubs merit protection for their value as community and heritage assets, whether designated or undesignated. This may include their intrinsic value as longstanding community facilities irrespective of any architectural or historic merit they may possess. Inclusion of a pub on this list does not imply that it would necessarily qualify as an asset of community value under Section 87 of the Localism Act 2011.”

It is requested that clarity is provided in the reasoned justification that proposals affecting sports facilities will be assessed against Policy CS4: Sports Provision as this policy is specifically intended for assessing development proposals affecting sports facilities. The scope of community facilities is often interpreted to include sports facilities especially indoor sports facilities such as leisure centres and swimming pools. As the criteria in policies CS1 and CS4 are different there is a risk of potential confusion about which policy should be applied to sports facilities and developers may exploit this by making the case that CS1 applies if this offers them more potential for compliance with the Local Plan than CS4. Furthermore, Policy CS4 has prepared to be consistent with paragraph 104 of the NPPF which specifically relates to sports facilities. Policy CS1 covers a broader range of community facilities and therefore the criteria are not the same as those in paragraph 104 of the NPPF

IT'S HARD TO GET A DOCTORS APPOINTMENT NOW. THE LOCAL SURGERY ISN'T BIG ENOUGH FOR THE EXTRA PEOPLE

no understanding of community need

Draft Policy CS1 focuses on ensuring there is sufficient community and social infrastructure to meet
the identified local need and seeks to do so through the inclusion of requirements to be demonstrated
where a proposed development results in the loss of an existing facility. NHSPS supports the
provision of sufficient, quality community facilities but does not consider the proposed policy
approach to be effective in its current form. Where healthcare facilities are included within the Local’s
Plan definition of community facilities, policies aimed at preventing the loss or change of use of
community facilities and assets can potentially have a harmful impact on the NHS’s ability to ensure
the delivery of essential facilities and services for the community.

The NHS requires flexibility with regards to the use of its estate to deliver its core objective of
enabling excellent patient care and support key healthcare strategies such as the NHS Long Term
Plan. In particular, the disposal of sites and properties which are redundant or no longer suitable for
healthcare for best value (open market value) is a critical component in helping to fund new or
improved services within a local area. Requiring NHS disposal sites to explore the potential for
alternative community uses and/or to retain a substantial proportion of community facility provision
adds unjustified delay to vital reinvestment in facilities and services for the community.

All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service
provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are
re-invested in the provision of healthcare services locally and nationally. The decision about whether
a property is surplus to NHS requirements is made by local health commissioners and NHS England.
Sites can only be disposed of once the operational health requirement has ceased. This does not
mean that the healthcare services are no longer needed in the area, rather it means that there are
alternative provisions that are being invested in to modernise services.

Where it can be demonstrated that health facilities are surplus to requirements or will be changed
as part of wider NHS estate reorganisation and service transformation programmes, it should be
accepted that a facility is neither needed nor viable for its current use, and policies within the Local
Plan should support the principle of alternative uses for NHS sites with no requirement for retention
of a community facility use on the land or submission of onerous information. To ensure the Plan is
positively prepared and effective, NHSPS are seeking the following modification (shown in red italics)
to Draft Policy CS1 or as an addition in supporting paragraphs to ensure the principle of alternative
uses for NHS land and property will be fully supported:

Proposed modification to Draft Policy CS1:
“Any proposal that would result in the loss of a site or building currently or last used for, or allocated
for the provision of community / social infrastructure including community facilities, services,
leisure or cultural activities that benefit the community, will only be supported in cases where the
Council is satisfied that:

a. An alternative, equivalent community facility to meet local needs is, or will be, provided in
an equally or more accessible location within a minimum walking distance of the locality
(800m or the minimum distance based on that appropriate for the facility being provided
as set out in the relevant evidence); or
b. It has been proven to the satisfaction of the Council that there is no longer a proven need
for the community facility; and
c. It has been proven to the satisfaction of the Council based on written evidence as detailed
in a-c below, submitted with the Planning Application, that it would not be economically
viable to retain the site/building for the existing or an alternative community use; and (in all
cases)
d. The community facility could not be provided or operated by either the current occupier or
by any alternative occupier, and it has been marketed to the satisfaction of the Council in
order to confirm that there is no interest for any community use and the site or building is
genuinely redundant.

Where healthcare facilities are formally declared surplus to the operational healthcare
requirements of the NHS or identified as surplus as part of a published estates strategy or service
transformation plan, the requirements listed under Part (a) to (d) above will not apply.”

Proposed addition to supporting paragraphs:
“Where healthcare facilities are formally declared surplus to the operational healthcare
requirements of the NHS or identified as surplus as part of a published estates strategy or service
transformation plan, the requirements listed under Part (a) to (d) will not apply.”

Proposed Housing Allocations Affecting Copford with Easthorpe Parish
The Regulation 18 Draft Local Plan proposes two major housing allocations affecting Copford with Easthorpe Parish:
• Policy PP29 – Land east of School Road, Copford: approximately 300 homes
• Policy PP17 – Land behind shops off London Road, Marks Tey: approximately 1,500 homes, crossing the Marks Tey / Copford parish boundary, with an estimated 600 homes located within Copford with Easthorpe Parish
Together, these allocations represent an additional 900 homes within the Parish. Based on an average household size of three people, this equates to an increase of approximately 2,700 residents.
While I recognise the need to identify sites to meet the City-wide housing target of approximately 21,000 new homes, I have serious concerns about where and how these homes are proposed and whether the necessary infrastructure can realistically be delivered. The scale of development proposed for Copford with Easthorpe Parish is neither fair nor proportionate.
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Conflict with the Vision and Objectives of the Local Plan
Section 2 (paragraph 2.19) of the Draft Local Plan sets out a vision of:
• “preserving Colchester’s identity” and
• “improving the quality of life of our residents”.
These are objectives I strongly support. However, the sheer scale of development proposed under PP17 and PP29 will have a significant and overall negative impact on this area. The scale, density and location of the proposed sites do not preserve local identity, rural character or biodiversity, and are therefore inconsistent with the stated vision of the Plan.
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Policy PP29 – Impact on Rural Character and Heritage Assets
The proposed housing density under PP29 would result in a substantial erosion of the rural nature of the Parish.
While the seven Grade II listed buildings and the Copford Green Conservation Area may not be directly affected by the development boundary, they will be adversely impacted by the inevitable increase in traffic, noise and pollution generated by the proposal.
Although the Draft Local Plan refers to a City-wide Housing Needs Survey, it makes no reference to the Copford Local Housing Needs Survey, which should be a material consideration when assessing local housing requirements.
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Policy PP17 – Cross-Boundary Development Concerns
With regard to Policy PP17, it is notable that Colchester City Council has recently refused an application for 175 homes in Tiptree, citing cross-boundary planning issues. Given this precedent, it logically follows that a proposal for 1,500 homes straddling the parishes of Marks Tey and Copford with Easthorpe should be subject to the same concern and scrutiny.
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Infrastructure Constraints
In addition to the scale of development, I have serious concerns about whether essential infrastructure can support these allocations.
Wastewater Treatment and Water Supply
Copford Water Recycling Works has very limited remaining capacity, with only 33% permitted Dry Weather Flow (DWF) capacity remaining (Colchester Water Cycle Study – Interim Findings, February 2025). The study identifies a “high risk of water quality non-compliance”.
While the interim AECOM report suggests sufficient water supply for new development, it does not specify where this additional water will come from. There has been speculation that this will rely heavily on reducing domestic water consumption to below 100 litres per person per day, an assumption that is both uncertain and unrealistic. Furthermore, the report does not account for wastewater and water supply requirements arising from existing allocations, let alone new ones.
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Road Network and Transport Impacts
There are already significant and well-documented problems on both the A12 and A120, with conditions on the A120 widely acknowledged as severe and unsustainable.
Additional housing will place further strain on these routes and will inevitably impact local roads, particularly:
• London Road (B1408), and
• School Road, the likely access route for PP29.
School Road is a major route to and from Copford Primary School, is already heavily congested at peak times, and is increasingly used as a rat run towards the A12 via Easthorpe Road and from Maldon Road via Fountain Lane and Aldercar. It is also used by HGVs.
Traffic generated by PP29 alone could result in up to 600 additional vehicle movements per day, significantly worsening congestion, pollution and road safety risks. This is of particular concern given the large number of children crossing School Road daily to attend the primary school. The proposal is therefore likely to result in an unacceptable impact on highway safety, and it is difficult to see how the policy objective of “safe pedestrian access” can realistically be achieved.
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Active Travel and Public Transport
Policy ST1 – Health and Wellbeing promotes active travel, which is commendable in principle. However, it is difficult to see how increased walking and cycling can be realistically achieved in the context of:
• higher traffic volumes,
• increased congestion, and
• safety concerns along School Road, London Road (B1408) and the A120.
Rather than promoting healthier lifestyles, the development risks leading to:
• increased noise and air pollution,
• compromised air quality, and
• wider environmental harm.
The suggested mitigation of a modal shift towards public transport is also problematic. Public transport options are limited to bus services on London Road, which are infrequent outside peak hours and become increasingly poor the further one travels from the city centre. In these circumstances, private car use is likely to remain the dominant mode of transport.
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Impact on the Local Environment and Biodiversity
Policy PP29 and Policy EN4 – Irreplaceable Habitats
The PP29 site lies adjacent to Pits Wood Local Wildlife Site. The proposed 15-metre buffer is inadequate given the sensitivity of the site and the presence of:
• large badger setts, and
• a population of nesting nightingales, a Red List endangered species.
The Woodland Trust recommends significantly larger buffer zones for development adjacent to ancient or sensitive woodland habitats. It is essential that full, seasonal ecological surveys are undertaken before any allocation is confirmed.
The potential enhancement of wildlife corridors linked to the Roman River corridor is welcomed, but this does not offset the likely harm arising from development at this location.
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Health and Wellbeing – Healthcare Provision
The delivery of Policy ST1(f) relating to healthcare provision is questionable. Local GP surgeries are already operating at or beyond capacity and would be unable to accommodate the additional population generated by approximately 1,800 new homes, in addition to the 630 homes planned in Stanway. There are also ongoing concerns regarding hospital capacity.
Any new development must be accompanied by properly funded healthcare provision, including staffing, to meet the needs of a significantly increased population.
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Community Facilities
Policies CS1 and CS2
Copford Village Hall is a well-used and financially viable community facility. While PP29 refers to its potential replacement, there are serious concerns:
• The Village Hall and associated land are registered with the Charity Commission, yet Draft Local Plan mapping suggests this land could be used for housing or access.
• Any transfer or redevelopment would require detailed negotiations between the developer, the Charity Commission and the current Trustees.
• An alternative approach could involve remodelling the existing hall and improving parking provision.
The local community must be fully involved in any decisions regarding the location and design of a new or improved Village Hall. The existing car park plays a vital role during the school run, helping to reduce on-street parking and congestion on School Road.
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Education Provision
While the inclusion of a two-form entry primary school within PP17 is welcomed, this does not adequately address the combined impact of 300 homes from PP29 and 1,500 homes from PP17. Copford Primary School is already near capacity and would require significant investment to accommodate additional pupils.
There is also no clear information regarding provision for secondary or post-16 education. Local secondary schools are already close to capacity, and the projected increase in pupil numbers cannot be accommodated without substantial new provision.

The Crime and Disorder Act 1998 places a duty on local authorities to reduce crime and
disorder within the community.
2. The National Planning Policy Framework 2024 requires the planning system to be plan
led, with plans contributing to the achievement of sustainable development - being shaped
by early, proportionate and effective engagement between plan makers and infrastructure
providers, to set out the infrastructure contributions expected from development.
3. Essex Police is an essential social infrastructure provider in this respect, who works closely
with neighbourhoods to provide community safety, cohesion and policing in line with the
objectives and priorities set out in the Police & Crime Plan 2024-2028 to support the
creation of safe, strong, healthy, resilient and sustainable new communities.
4. With this in mind, Essex Police submitted evidence to inform the infrastructure scoping
process at the earlier (stakeholder) stages of the local plan review, linked to preparation of
the Colchester Infrastructure Audit & Delivery Plan (IADP) in December 2024 and June
2025, which is retained by the City Council as background documentation.
5. The IADP Stage 3 Report dated 24 October 2025 therefore outlines the Essex Police
infrastructure requirements to mitigate and manage the planned housing/ population
growth over the plan period to 2041.
6. The Essex Policing Model is outlined in the IADP and reproduced below for information.
Essex Policing Model
7. To use resources efficiently to address the incidence of crime and engage effectively with
the local community, Essex Police operates a ‘Local Policing Area’ (LPA) policing model.
8. Each Local Policing Area is resourced by a dedicated Neighbourhood Policing Team (NPT),
consisting of Police Officers, Police Community Support Officers (PCSO’s), Community
Safety Engagement Officers, Children & Young Persons Officers and integrated local
partners and partnerships within co-located Community Safety Hubs.
9. This resourcing structure ensures that an appropriate level of response is coordinated at
the outset, ranging from a routine community safety/ cohesion deployment to a serious
crime response, to meet the community’s needs.
10. Both the construction and occupation phases of residential development lead to an
increase in the incidence of criminal activity . At the construction phase this includes property-based theft and vandalism, as
acknowledged by the Chartered Institute of Building in its publications concerning Crime in
the Construction Industry. Such incidents lead to an increased impact on police facilities
and a greater draw on Essex Police NPT resources.
12. At the occupation phase increased populations give rise to an increase in crime and
incidents against the person (e.g. violence, sexual, burglary, vehicle theft and criminal
damage). New residents would be the victims of such crime, leading to an increased impact
on police facilities and a greater draw on its NPT resources, including specialist unit support
officers.
13. Emerging new communities need to be integrated with existing communities, and an
appropriate level and duration of community safety, cohesion and policing would therefore
need to be provided across the occupation phases of developments.
14. Major new housing developments give rise to significant additional resource needs and
implications for NPT’s, (including specialist officers supporting the NPT’s), requiring
appropriate developer funding in order to mitigate and manage the community safety,
cohesion and policing requirements, including the crime impacts arising.
Police Infrastructure & Facilities (Police Facilities)
15. In the context of the Essex - wide plan making and development management processes,
police facilities are defined as follows;
❖ Additional or enhanced police station (Local Policing Team) floor space & facilities,
including fit out & refurbishment;
❖ Custody facilities;
❖ Mobile police stations;
❖ Communications, including ICT;
❖ Speed Camera/ Automatic Number Plate Recognition Technology;
❖ Police vehicles;
❖ Funding for additional staff resources, incorporating the recruitment, training,
equipping & tasking of Police Community Support Officers (PCSO’s) during the
construction phase of residential development, & recruitment, training equipping of Local Policing Team Officers (LPTO’s) during the occupation phase of
residential development;
16. The developer funded police facilities required to mitigate and manage the impact arising
on Essex Police service capacity (and related costs) are outlined in the IADP.
Local Plan Text & Policy Revisions
17. Essex Police is satisfied that the IADP reflects its budgetary evidence concerning the level
of developer funded police facilities required to mitigate and manage the planned housing/
population growth within the Colchester City Council area to 2041.
18. Essex Police is not currently satisfied, however, that the text and policies within the
Preferred Options Local Plan Regulation 18 Consultation are sufficiently justified or
comprehensive, as they are not considered to;
❖ Identify Essex Police as an essential social infrastructure provider – requiring
developer funding in order to mitigate & manage the impacts arising from
planned housing/ population growth;
❖ Essex County Fire & Rescue Service & the East of England Ambulance Service NHS
Trust are also not identified as essential infrastructure providers;
❖ Provide sufficient clarity concerning the requirement for developer funded police
infrastructure/ facilities in association with the strategic housing sites >250
dwellings;
❖ Provide sufficient recognition concerning the definition of ‘infrastructure’ being
applicable to police infrastructure/ facilities (police facilities) – this position is
equally applicable to fire & rescue & ambulance facilities;
❖ Provide adequate recognition to the wider remit & role of Essex Police in providing
community safety, cohesion & policing in contributing to the delivery of sustainable
new communities, in addition to its duties as a Category 1 Responder under the
Civil Contingencies Act 2004 (i.e. its emergency service role) - this position is equally
applicable to fire & rescue & ambulance facilities;
19. A Schedule of Text & Policy Changes outline the changes sought to the draft text and
policies contained in the Preferred Options Local Plan, which is submitted as an
Accompanying Document.
20. In addition, 16 x form-based representations outline the changes sought, and are
submitted as Accompanying Documents.
21. Essex Police commend the changes sought in its representations which are considered
necessary to provide for a justified and comprehensive local plan, and look forward to
continuing its productive working relationship with the City Council and its retained consultants to that end

Having looked at the document related to our topics of interest, we are supportive of the wording of Policy CS1 (Retention of Community Facilities) as well as CS2 and would not seek any further amendments