as previous

Direct impact on Bridleway 233 Myland and Bridleway 233 Myland. Riding is already severely limited on this side of Colchester, and these bridleways must be preserved at all costs. Suggest to upgrade Footpath 231 Myland to create a safe crossing point for walkers, cyclists and equestrians. PRoW should be linked to Bridleway 232 Myland, which will result in another crossing point that is linked by road to Bridleway 45 Langham to create a continuous, off-road, safe network to encourage access to green space and the countryside. Cycleways must be designed as multi-user routes to ensure inclusivity for all non-motorised users.

This site already has planning permission 190665 for a variety of uses. The plan misses an opportunity to update them in a post-Covid world. It needs to indicate that high density housing will be acceptable on C2 which is unlikely to ever be developed as offices: and that flexibility will be shown around HC1 and HC2 which is unlikely ever to become the health campus originally envisaged.

The suggestion that only 350 dwellings can be accommodated on the whole site does real damage to the prospects for development of this long-paralysed strategic site. Much more is possible.

The ICB would wish to be involved from early inception of specialist accommodation development so that it can interject important health information for specific areas before planning applications can progress. There are possible locations that could accommodate more specialist accommodation than others and working together to identify these areas could be a useful way of trying to mitigate the impacts on PCNs going forward.

The ICB would want it noted that although it mentions possible provision for health care within this development, it has not been discussed with the ICB and is speculative on the part of CCC.

The attached heat map shows the ideal location area for a new Ambulance Hub – 1ha of land is required to facilitate this.

Utilise heat capture from data centres to support heating of residential & commercial properties

Please refer to attached representations.

IPIF’s freehold interest in the land north of Axial Way comprises two main parcels of land outlined in red in
Figure 1 below. The entire area shaded in red represents land within IPIF’s freehold ownership, while the
smaller areas shaded in yellow are outside IPIF’s ownership. The land splitting the two main parcels is owned
by Colchester City Council.
The eastern parcel predominantly comprises landscaped open space associated with the large industrial unit
located immediately to the north. This area includes a number of mature trees around its perimeter, with a
particularly dense tree line along the eastern boundary. A vehicular access from Axial Way to the south crosses
the site, providing access to the industrial unit.
The western parcel comprises a cluster of smaller rectangular industrial and commercial units arranged around
internal estate roads with service yards and car parking positioned adjacent to each unit.
2
Figure 1: Site Location – Land North of Axial Way
Surrounding Area
The surrounding context is characterised by a mix of employment and residential uses. To the north, the site
adjoins a substantial industrial building with associated car parking and hardstanding, beyond which lies the
A12. To the south, Axial Way runs broadly east to west, with the grounds of Colchester Rugby Football Club
situated on the opposite side of the road. To the east, the site is bordered by a relatively new residential
development, with smaller industrial units and residential blocks located further beyond. To the west, the site
is enclosed by additional industrial estates, reinforcing the area’s established employment character.
The site benefits from excellent connectivity. Junction 28 of the A12 is approximately 700 metres to the west,
providing direct access to the strategic road network. Colchester Station lies around 2.9 kilometres to the south,
offering frequent rail services to London Liverpool Street, Ipswich, and Clacton-on-Sea. Public transport
provision is strong, with multiple bus stops along Axial Way serving Severalls Park and Colchester City Centre;
two stops are located within a ten-minute walk of the site’s access point.
A hybrid planning application (LPA Ref. 190665) was approved by Colchester City Council for the
redevelopment of land south of Axial Way, known as Colchester Northern Gateway. The consent includes a
healthcare campus of approximately 5 hectares, comprising up to 300 older people’s homes (C3), a 4,300 sqm
private acute surgical hospital (C2), a 1,200 sqm medical centre (D1), a 3,600 sqm 75-bed care home (C2),
and up to 45,100 sqm of office space (B1a). It also permits up to 350 homes (C3) alongside ancillary retail and
food uses. Based on the approved plans, the land immediately south of Axial Way, opposite the IPIF freehold,
is designated for healthcare and residential development.
Comments on the Colchester City Council Preferred Options Local Plan
Policies Map
Within the current Local Plan IPIF’s land holding lies within the following designations:
• Colchester Settlement Boundary
• North Growth Area
• North Colchester Strategic Employment Zone / Employment Zone
3
These designations reflect the area’s established and strategic role for employment and economic activity. An
extract of the adopted policies map is included at Figure 2 below for reference.
Figure 2: Extract of adopted policies map (with IPIF’s holding outlined in red)
With reference to the draft Policies Map as part of the Regulation 18 consultation the ‘North Colchester Strategic
Employment Zone / Employment Zone’ designation (or similar) seems to have been omitted. This is shown at
Figure 3 below.
Figure 3: Extract of emerging policies map (with IPIF’s holding outlined in red)
This omission seems odd given the wording of draft Policy E1 (Protection of Employment) which talks about
defined areas on the polices map; unless the defined areas are only meant to cover new employment provision.
This is currently unclear within the consultation document. We would respectfully request clarity on this matter.
4
These comments are made in the context of IPIF identifying an opportunity to develop two underutilised parcels
of land within their holding to deliver additional employment floorspace. These parcels are shown in Figure 4
below.
Figure 4: IPIF Development Parcels
The two parcels currently comprise managed landscaping historically associated with the unit to the rear. These
parcels are hugely underutilised given their location and can better help to contribute towards the Council’s
economic need. It is noted that the latest Employment Study (February, 2025), prepared as part of the evidence
base for the new Local Plan, estimates that there is a net additional demand for 41.7ha of employment land
across Colchester over the plan period.
If the Council’s intention is not to include a wider employment designation within the new Local Plan which
covers IPIF’s holding, then it is respectfully requested that the two parcels above are allocated for employment
development (Use Classes B2 / B8 / Eg). This would then establish the principle of employment development
for the parcels.
Policy E1 (Protection of Employment)
We note that draft Policy E1 looks to safeguard land and premises for Class E(g), B2, and B8 uses. Whilst the
list of uses is supported, Policy E1 should also allow for associated Sui Generis uses or small scale supporting
uses which sit outside of Class E(g), B2, and B8. This is to help support the primary function of such land and
premises. This is especially true on larger employment estates where uses such as a nursery, gym, or café
can help support the wider work force.

Direct impact on bridleways 233 and 232. I suggest upgrading FP 231 to create a crossing point.
Active travel includes horse riding

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

Please refer to submitted representation.

Our Colchester BID would like to see business uses maintained at street/ground floor level within the whole of the city centre/Primary Shopping Area. It would not object to upper floors above street/ground floor level being utilised as residential where appropriate. It may object to any change of use at street/ground floor level.
It would formally object to any HMO application within the city centre on the grounds of:
• Impact on commercial character and community cohesion
• Parking and traffic congestion
• Strain on local infrastructure
• Safety and anti-social behaviour (ASB)

and feels this use would be wholly inappropriate within the city centre/Primary Shopping Area. It would further insist that a Housing Health and Safety Rating System (HHSRS) assessment be rigorously carried out before any final planning permission is granted.
Policy PP1: Britannia Car Park, Colchester
Our Colchester BID is unable to support the change of use of this car park to residential because it undermines the shared objective of a thriving, accessible and resilient city centre economy. The BID’s overriding priority is to safeguard the trading environment for businesses in Colchester city centre and the BID zone and to ensure policy decisions support, rather than weaken, that goal.
- Protecting city centre businesses
Our Colchester represents the collective interests of hundreds of levy-paying businesses whose success depends on reliable access for customers and staff. The proposed loss of centrally located spaces at Britannia Car Park would materially reduce capacity at the very point of access closest to key retail, hospitality, cultural and professional services in the BID area, increasing perceived and actual barriers to visiting the city centre.
City centre businesses already face structural pressures from online retail, out of town destinations and rising operating costs, and parking availability is a critical factor in decisions about where people shop, eat and spend leisure time. Any policy that removes a major provision of convenient parking without guaranteed, like for like alternatives risks depressing footfall, shortening dwell time and weakening business confidence across the BID zone.
- Policy context and regeneration aims
Our Colchester recognises and supports the Council’s wider objectives around climate action, sustainable transport and city centre regeneration, including the Positive Parking Strategy and related infrastructure upgrades. These objectives can and must be delivered in a way that keeps the city centre commercially viable, protects existing employment and underpins investment in new jobs and spaces within the BID area.
However, the redevelopment of Britannia Car Park must not proceed on the assumption that demand can simply be displaced to other locations or modes in the short to medium term. Even with planned improvements at alternative car parks and investment in public transport, the removal of this single asset represents a step change in capacity that will be felt most acutely by small and medium sized enterprises whose customers value proximity, convenience and perceived safety, particularly in the evening economy.
- Impact on staff, recruitment and inclusion
The BID is particularly concerned about the impact on employees working in the city centre, many of whom rely on Britannia Car Park for early morning, late night or shift pattern access when public transport options are limited. A substantial reduction in central parking risks making it harder for businesses to recruit and retain staff, raising costs and reducing the attractiveness of BID area employment compared with other locations.
There is also a risk that reduced central parking capacity will disproportionately affect workers and customers with mobility needs, caring responsibilities or safety concerns about travelling longer distances on foot, especially at night. Any policy change must therefore be assessed not only against environmental and transport metrics but also against equality, inclusion and safety impacts on those who depend on convenient access to the city centre.

- Colchester City Council research
Colchester City Council’s research may suggest that closing Britannia Car Park will not reduce total parking capacity across the wider city. Still, Our Colchester continues to believe the closure would significantly harm businesses, staff and customers in the city centre and BID zone. The core concern is not just how many spaces exist in total, but where those spaces are located, how easy they are to use, and what this means for the trading environment.
- Why “no net loss” still harms businesses
Even if overall city wide parking numbers remain stable on paper, removing spaces in one highly central, well used location changes behaviour in ways that affect businesses. Spaces that are further away, harder to find, or perceived as less safe in the evening are not equivalent for customers who want convenient access to shops, hospitality and services in the BID area.
“Spare” capacity in distant or less attractive car parks does not compensate for the loss of a major gateway site that many regular visitors habitually use. For time pressed visitors, families, older people and those travelling in from surrounding areas, added distance, complexity or uncertainty can be enough to deter a trip altogether or shorten their stay, directly impacting footfall and spend for city centre businesses.
- Challenging the assumptions in the Council’s evidence
The Council’s modelling appears to focus on typical occupancy across all city centre car parks, often showing spare capacity at certain times of day or week. However, this approach smooths out peak pressures and does not fully capture pinch points such as weekends, events, bad weather or the evening economy, when the convenience of a location like Britannia matters most.
There is also a difference between what is technically available and what people actually use in practice. Behavioural factors such as driver familiarity, signage, real time information, perceived safety and walking routes to key destinations are critical to how “usable” a space really is. If drivers struggle to find or feel comfortable using alternative car parks, the theoretical spare capacity will not translate into real world support for the BID area economy.
The BID is ready to work constructively with the Council, transport providers and developers to co design solutions that align with net zero and regeneration ambitions while protecting the commercial core that funds local services, supports thousands of jobs and underpins Colchester’s role as a leading city in the region. Until such safeguards are in place, Our Colchester must firmly oppose the closure of Britannia Car Park in its current form and will continue to advocate for policies that put the long term health of BID area businesses at the centre of decision making.


Policy PP2: Vineyard Gate, Colchester
Our Colchester BID is unable to support the change of use of this car park to residential because it undermines the shared objective of a thriving, accessible and resilient city centre economy. The BID’s overriding priority is to safeguard the trading environment for businesses in Colchester city centre and the BID zone and to ensure policy decisions support, rather than weaken, that goal.
- Protecting city centre businesses
Our Colchester represents the collective interests of hundreds of levy-paying businesses whose success depends on reliable access for customers and staff. The proposed loss of centrally located spaces at Vineyard Gate Car Park would materially reduce capacity at the very point of access closest to key retail, hospitality, cultural and professional services in the BID area, increasing perceived and actual barriers to visiting the city centre.
City centre businesses already face structural pressures from online retail, out of town destinations and rising operating costs, and parking availability is a critical factor in decisions about where people shop, eat and spend leisure time. Any policy that removes a major provision of convenient parking without guaranteed, like for like alternatives risks depressing footfall, shortening dwell time and weakening business confidence across the BID zone.
- Policy context and regeneration aims
Our Colchester recognises and supports the Council’s wider objectives around climate action, sustainable transport and city centre regeneration, including the Positive Parking Strategy and related infrastructure upgrades. These objectives can and must be delivered in a way that keeps the city centre commercially viable, protects existing employment and underpins investment in new jobs and spaces within the BID area.
However, the redevelopment of Vineyard Gate Car Park must not proceed on the assumption that demand can simply be displaced to other locations or modes in the short to medium term. Even with planned improvements at alternative car parks and investment in public transport, the removal of a single asset represents a step change in capacity that will be felt most acutely by small and medium sized enterprises whose customers value proximity, convenience and perceived safety, particularly in the evening economy.
- Impact on staff, recruitment and inclusion
The BID is particularly concerned about the impact on employees working in the city centre, many of whom rely on Vineyard Gate Car Park for early morning, late night or shift pattern access when public transport options are limited. A substantial reduction in central parking risks making it harder for businesses to recruit and retain staff, raising costs and reducing the attractiveness of BID area employment compared with other locations.
There is also a risk that reduced central parking capacity will disproportionately affect workers and customers with mobility needs, caring responsibilities or safety concerns about travelling longer distances on foot, especially at night. Any policy change must therefore be assessed not only against environmental and transport metrics but also against equality, inclusion and safety impacts on those who depend on convenient access to the city centre.

- Colchester City Council research
Colchester City Council’s research may suggest that closing Vineyard Gate Car Park will not reduce total parking capacity across the wider city. Still, Our Colchester continues to believe the closure would significantly harm businesses, staff and customers in the city centre and BID zone. The core concern is not just how many spaces exist in total, but where those spaces are located, how easy they are to use, and what this means for the trading environment.
- Why “no net loss” still harms businesses
Even if overall city wide parking numbers remain stable on paper, removing spaces in one highly central, well used location changes behaviour in ways that affect businesses. Spaces that are further away, harder to find, or perceived as less safe in the evening are not equivalent for customers who want convenient access to shops, hospitality and services in the BID area.
“Spare” capacity in distant or less attractive car parks does not compensate for the loss of a major gateway site that many regular visitors habitually use. For time pressed visitors, families, older people and those travelling in from surrounding areas, added distance, complexity or uncertainty can be enough to deter a trip altogether or shorten their stay, directly impacting footfall and spend for city centre businesses.
- Challenging the assumptions in the Council’s evidence
The Council’s modelling appears to focus on typical occupancy across all city centre car parks, often showing spare capacity at certain times of day or week. However, this approach smooths out peak pressures and does not fully capture pinch points such as weekends, events, bad weather or the evening economy, when the convenience of a location like Vineyard Gate matters most.
There is also a difference between what is technically available and what people actually use in practice. Behavioural factors such as driver familiarity, signage, real time information, perceived safety and walking routes to key destinations are critical to how “usable” a space really is. If drivers struggle to find or feel comfortable using alternative car parks, the theoretical spare capacity will not translate into real world support for the BID area economy.
The BID is ready to work constructively with the Council, transport providers and developers to co design solutions that align with net zero and regeneration ambitions while protecting the commercial core that funds local services, supports thousands of jobs and underpins Colchester’s role as a leading city in the region. Until such safeguards are in place, Our Colchester must firmly oppose the closure of Britannia Car Park in its current form and will continue to advocate for policies that put the long term health of BID area businesses at the centre of decision making.


Policy PP6: Land at Colchester North Station Mixed Used
This area is allocated mixed use, OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy OA4 Northern Gateway
a. Provision of approximately 650 new dwellings of a mix and type of housing to meet evidenced needs which is compatible with surrounding development;
b. Provision for employment on land north of Axial Way as shown on the policies map allocated for employment, primarily for office use within E class;
Reference b. OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre. We would consider the employment use to be for professional services/office provision.
Our Colchester welcomes the council’s requirements for any small retail / leisure uses within this local centre must be subject to the requirements of Policy E4 in respect of the sequential test and for proposals above 350sqm gross floorspace a retail impact assessment will also be required.
Policy PEP3 Land South of Tollgate West
Our Colchester BID would not like to see any more significant retail offered at this location. The existing Tollgate offering together with Stane Park are already a major retail attraction pulling custom away from the city centre/ Primary Shopping Area. Any further expansion of retail will significantly impact the economic viability of the city centre and pull even more custom away.
Policy PP9: North-East Colchester
Although this area is allocated as residential OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PP10: Land South of Berechurch Hall Road, Colchester
Although this area is allocated as residential OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Growth and Opportunity Areas : Hythe Opportunity Areas consisting of : Policy OA1: King Edward Quay Opportunity Area/ Policy OA2: Land East of Hawkins Road Opportunity Area
These areas are likely to be allocated to residential, OurColchester BID would not like to see any significant retail development offered as it would threaten and likely dilute the retail offering of the city centre.
Marks Tey Growth Area consisting of : Policy PP18: Land North of A120, Marks Tey Growth Area: Policy PP18: Land North of A120, Marks Tey Growth Area
Although this area is allocated as residential OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PEP5 Land South of A12, Marks Tey
This area is allocated to employment, OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PEP6 Anderson's Site, Marks Tey
This area is allocated to employment, OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PEP7 Highland Nursery, Tiptree
This area is allocated to employment, OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PEP8 Land South of Factory Hill, Tiptree
This area is allocated to employment, OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.
Policy PP19: Land North of Oak Road, Tiptree
Although this area is allocated as residential OurColchester BID would not like to see any significant retail development offered at this site as it would threaten and likely dilute the retail offering of the city centre.