as previous

This has not been seen as Colchester has grown as we only have 1 community swimming pool with poor cleanliness and poor accessibility. Other facilities have not grown to broaden the spread across Colchester to increase accessibility.

Where building developments are planned in Layer de la Haye, they are on The Folley which is a narrow road with bends and no pavements. Any new development should plan to have public footpaths to aid safe passage for pedestrians and horse riders - especially those going to the school with children

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

Abberton and Langenhoe have no medical facilities and poor links to the Hospital

The current Village Hall site (PP29) is shown as being used for this development, it is currently financially viable and well used. If this site is to go forward urgent discussions are needed with the Village Hall Trustees and Charity Commission- to whom this site is registered.

Nothing more can enhance the village because of the A120

Enhancement of and Provision for Community Facilities Policy CS2
Noted there is a deficit of some £811,438,036 in Infrastructure funding. This equates to adding some £40,000 to each dwelling built in way of an infrastructure levy via CIL or Section 106. There is considerable concern therefore that infrastructure improvements required will not be forthcoming from the Local Plan.

West Bergholt Parish Council supports this policy.

P128

The ICB will endeavour to identify cumulative impacts in the IDP and look to use CIL/equivalent infrastructure levy to part fund the larger projects. It is important that health facilities are protected from intrusive growth that could impact on facilities extending into adjacent land as part of meeting the increase in population from development.

Again I have no issue with the Policy, just a concern that developers won't fulfil there obligations to provide the necessary facilities. For PP9 I note there is a mention of primary school and early years provision, but worryingly nothing on healthcare facilities, despite the local surgery (Parson's Heath Medical Practice) being at capacity and not accepting new patients. Although even if a new surgery was provided staffing it would prove difficult. I'm also concerned that developers are not always forthcoming with Section 106 payments, evidenced by the number of Councils chasing payments.

Despite recent development of West Mersea Island - with 200 additional homes - the gains to the community have been minimal - either from development gains (because the sums are so insignificant in comparison to the costs for meaningful community projects, or any focus for the community with significant community assets from City Council Funds.

The Island lacks any real community assets with sports projects un-funded and the MICA centre significantly under-invested; and the Island's ageing population recreational and wellbeing needs under-invested and little considered.

West Mersea is instead considered an easy target for continued development by planners and developers.

Latimer supports the principal of Policy CS2 (Enhancement of and Provision for Community Facilities) which confirms that:
“Contributions may be pooled towards larger community infrastructure projects to cumulatively contribute towards provision on a larger scale where a need has been identified. Where existing facilities can be enhanced to serve new development, the Council will work with developers and local partners to audit existing facilities and deliver any requirements for such facilities to deliver comprehensive provision of services to serve these extended communities” (Lichfields emphasis).

This is important for Latimer as the TCBGC DPD requires Latimer to facilitate the delivery of significant new physical infrastructure (such as footways, cycleways, roads, and sewers); social infrastructure (including a further education college, new secondary school, primary schools, special educational needs and early years facilities, leisure uses and sports facilities); and green infrastructure (such as open, recreational spaces and a new country park).

These facilities will not only be used by and benefit future residents of the TCBGC development but will also be used by and be of benefit to existing and future residents in the surrounding area, including those living in Colchester.

Given the wider benefits of the TCBGC proposals, it is important to ensure that there is a mechanism in place whereby new development within or adjacent to the TCBGC allocation that will be reliant on this physical and social infrastructure will directly contribute towards the provision and/or maintenance of the TCBGC facilities, including assets that may be adopted by the Councils (Unitary or otherwise).

We note that CCC does not have a CIL Charging Schedule in place, nor does the ‘Local Development Scheme 2024-2027 (March 2025)’ indicate plans to prepare one in the near future. Accordingly, any funding of new or existing infrastructure must come from S106 contributions.
On this matter, the PPG is clear that s106 obligations can be pooled to fund infrastructure provided that Local Planning Authorities set out in an Infrastructure Funding Statement (IFS) which infrastructure they intend to fund and detail the different sources of funding:

“The 2019 amendments to the regulations removed the previous restriction on pooling more than 5 planning obligations towards a single piece of infrastructure.
This means that, subject to meeting the 3 tests set out in CIL regulation 122, charging authorities can use funds from both the levy and section 106 planning obligations to pay for the same piece of infrastructure regardless of how many planning obligations have already contributed towards an item of infrastructure.

Authorities should set out in an infrastructure funding statement which infrastructure they intend to fund and detail the different sources of funding (see regulation 121A).
Paragraph: 006 Reference ID: 23b-006-20190901” (Lichfields emphasis)

At present, CCC’s latest Infrastructure Funding Statement 2023/2024 does not do this. It solely “sets out income and expenditure relating to contributions secured through s106 Agreements on developments throughout Colchester.” (pg.3).
Accordingly, Latimer requests that future versions of CCC’s Infrastructure Funding Statement clearly identify the infrastructure that CCC intend to fund through pooled s106 contributions, including those infrastructure facilities proposed as part of the TCBGC development. This should also apply to any future Infrastructure Funding Statements that come forward through any future combined Unitary Authority as part of Local Government Reorganisation.

These future Infrastructure Funding Statements should draw on the Colchester Infrastructure Audit and Delivery Plan Stage 3 Report (AECOM, October 2025) in the Regulation 18 Local Plan evidence base (noting comments later in these representations) as well as the ‘Infrastructure Delivery, Phasing and Funding Plan (February 2023); from the TCBGC DPD evidence base.

Accordingly, and to ensure robustness of Policy CS2, Latimer would request that Policy CS2 specifically identifies CCC’s Infrastructure Funding Statement (and any future relevant Infrastructure Funding Statements) as the source of where the need for larger community infrastructure projects have been identified, as follows:

“Contributions may be pooled towards larger community infrastructure projects to cumulatively contribute towards provision on a larger scale where a need has been identified within CCC’s Infrastructure Funding Statement 2024/25 (and any future relevant Infrastructure Funding Statements). Where new or existing facilities can be enhanced to serve new development, the Council will work with developers and local partners to audit existing facilities and deliver any requirements for such facilities to deliver comprehensive provision of services to serve these extended communities”

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.