Should not be considering the use of current working farmland, there are other brown field sites. No consideration of environment and wildlife that dwell in that area. Bullock Wood which is protected, no concerns over water table. Lack of road infrastructure, traffic issues already exist on St John’s Road and surrounding areas. No consideration on the extra strains on schools, doctors currently in the area and the existing capacity issues with the General Hospital.

I wish to object to the allocation of 2000 extra houses for East Colchester, on top of the 7,500 already proposed through the Garden Community on the East of Colchester.

The SLAA Stage 2 document in its analysis of the St Johns site (p73) admits that there would be a loss of public open space, public right of way or bridleway and that the site is high quality agricultural land and entirely greenfield land - this cannot therefore be considered an appropriate site for this quantum of housing. When considered in combination with the Welshwood Park parcel, this would also be said to be contributing to coalescence, as this site has been analysed to do so - therefore these sites combined will contribute to a blurring of sense of place.

I am also concerned about biodiversity loss and threat to the ancient woodland which must be protected.

A major concern is the traffic implications of this allocation. The transport evidence document that has recently been published (October 2025) shows that East Colchester has the worst traffic outcomes in every scenario modelled - how can it be considered that it is therefore best to intensify all of the housing allocations to this side of Colchester?! Local roads will be gridlocked already as a result of the Garden Community that is coming forward, which it has already been admitted that the required transport infrastructure may not be provided. A further allocation of 2,000 houses in the same area cannot be coped with on the roads and will greatly impact existing residents.

My concerns about the proposed development at St John’s are as follows:
- Loss of green space for my family with small children, and the impact this will have on their health
- Roads not able to cope with increased traffic
- Already have issues with flooding/drainage: lack of ability to cope with additional waste water
- access to services - GP surgery already too busy on a site too small to expand
- my children will be starting school soon - huge concern re competition for school places in absence of additional schools included in plan

Loss of green space and associated eclectic flora and fauna, increase in already busy traffic areas and therefore air pollution, concern around local services provision eg schools/doctors, suspected loss of house value (house backs on to field with low fence), council lack of action/extensive delays in response to reported issues on flash flooding/standing water issues in immediate area suggests won’t be able to cope with associated issues with 2000 new homes, SSSI with historical significance (Bullock Wood) needs protecting and buffer zone already lacking/seemingly non-existent from previous adjacent developments off Ipswich Road.

The local roads cannot accommodate 2k cars or even up to 4k working on two per household per day.
Summer of 2025 we had a warning our local reservoir was very low, stopping short of a hose pipe ban. This development will bring that ban closer for those that depend on it.

Residential building of the scale proposed will destroy a significant factor contributing to the wellbeing of everyone in St John’s. The area could not cope with a population surge with transport, amenities & healthcare already strained. The standard of living for existing residents would be shattered, & any promise of a dream life for anyone choosing to move here would be soon met with disappointment when it becomes clear that the local infrastructure cannot handle 5,000 more people. That, & with hundreds of acres of ecologically important green space & quality arable farmland having vanished from the local landscape.

Ref Site IDs: 10616, 10616a and 10616b

Very concerning impact on biodiversity and habitats. This land is next to what is classed as ancient woodland, adjacent to two local wildlife sites ie Welshwood, Wall’s Wood and also the corridor of salary brook. It features a diverse range of wetland habitats, including priority habitat ‘Coastal and floodplain grazing marsh’ pasture, fishing ponds, grassland and has already been designated as a local wildlife site and local nature reserve because of this diverse wetland. Mature / veteren trees and ancient woodland is likely to be harmed by development even with the suggested 15 m buffer and Welshwood in particular is already seeing signs of this damage. There are so many manmade footpaths, compacted soils, eroded stream banks. Within the Habitat Regulation Assessment Development of this land will have significant effects, and the Biodiversity Protection and BNG study has identified that development of the fields would lead to biodiversity harm due to proximity of the designated sites and Local Wildlife Sites. Having seen protected species - grass snakes, newts, skylarks to name a few - regularly first hand over our time living here for 25 years we feel so strongly that this precious asset to Colchester’s wildlife desperately needs protection.

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

It’s hard to know quite where to begin as there are so many issues with this site allocation, but I’ll try and break it down into my main concerns.

Ecology
In addition to Welsh Wood LoWS and Wall’s Wood LoWS the area borders Bullock Wood SSSI on two of the three sides not already surrounded by housing. The fact that three protected sensitive sites are affected should have already set off alarm bells, but it is Bullock Wood I will concentrate on as that is the most significant. It’s definition as an SSSI already tells you that this is a nationally important resource. An ancient wood whose history can be traced back to at least 1242 and an irreplaceable nationally rare habitat. Your own Emerging Allocations Biodiversity Assessment of site 10256 (St John’s Fields) had a classification of “Harm” for this site saying “Development is likely to have a significant impact on the SSSI’s condition”, also Summary of Sites Evidence Colchester Local Plan October 2025 listed “Biodiversity Protection and BNG study Harm – Borders woodland SSSI and likely to have an adverse impact on it”. Therefore the following applies:
NPPF 2024, 193 (c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”.
Gov.uk, Ancient woodland, ancient trees and veteran trees: advice for making planning decisions “You should refuse planning permission if development will result in the loss or deterioration of ancient woodland, ancient trees and veteran trees unless both of the following applies:
- there are wholly exceptional reasons
- there’s a suitable compensation strategy in place (this must not be a part of considerations of wholly exceptional reasons) - see paragraphs 33 and 34 of the planning practice guidance on compensation guidance.
You should make decisions in line with paragraph 180 (c) (this references the 2021 version of the NPPF, the equivalent paragraph is 193 in the latest edition) of the NPPF. Ancient woodland, ancient trees and veteran trees are irreplaceable. Therefore, you should not consider proposed compensation measures as part of your assessment of the merits of the development proposal.

Your own Policy EN1 states “Development proposals that have adverse effects on the integrity of habitats sites or Sites of Special Scientific Interest, either alone or in-combination, will not be supported.”

I don’t know how this can be any clearer and should have in itself ruled out the site for possible development. The wood relies on drainage from the surrounding fields, so any changes to this drainage pattern due to construction could damage the sensitive nature of it’s eco system. Further areas of damage to the integrity of the wood itself and the wildlife that rely on it would come from light, noise and air pollution, encroachment from human activity, pollution from run-off, introduction of invasive species and loss of connectivity with other green spaces.

Only very basic ecology surveys seem to have been done at the moment, just giving a snapshot of the biodiversity on the site. Surveys would need to be done spread throughout the year to give a true picture so that informed decisions on the site could be made. Just doing one survey is the equivalent of checking the weather on one day of the year then assuming every other day will be the same. I know that skylarks nest on the fields and that bats use the margins of the wood and hedgerows for foraging. Also bats roost in the old wooden barn next to St John’s Cottages. Badgers move between the Bullock Wood and Welsh Wood areas. Kestrals, Buzzards and now Red Kites can all be seen over the fields. Any development would also result in the loss of Grade 2 agricultural land, when we are supposed to be concerned about food security. The Sustainability Appraisal Report assesses SA2 “Efficient use of land” and SA8 “Biodiversity and geodiversity” for site 10256a as Significant Negative.

There is much talk of protection for and improvement of the ecology and biodiversity of the area, but this feels like hollow words. Although I have argued strongly against this, if development was to be allowed a significant area of land could not be built on because of the need provide a substantial buffer to Bullock Wood, which should be at least 100m, as per Woodland Trust recommendations, with also buffering to the existing hedgerows and ditches. Space would also be needed to store surface water run-off as per 7.17 of the Consultation, which cannot be within the buffering zones. If the Council truly values nature wouldn’t it be great if they bought Bullock Wood from it’s private owner, so that it could then properly manage it itself, or donate it and the buffering zone to Essex Wildlife Trust. That would actually be something I could really support.

I have spent a long time on the subject of ecology as that is my primary concern, although there is far more I could say. However there are many other concerns. I will try to cover some of these briefly.

Local Amenity
The footpaths around the fields of PP9 are used extensively by local residents, providing an invaluable resource for exercise, connection with nature and general wellbeing. Developing the area will destroy this open space and there is no close alternative or ways to replace it. I have lived on St John’s Estate for 59 of my 61 years, so obviously feel a strong connection with this space. I played there with my friends. I still walk there. I can enjoy it even just cycling past it on the A137 when heading out for a ride, perhaps seeing a kestrel hovering over the verge hunting or hearing the skylarks singing. To think this could be lost is what is driving me to spend many hours going through endless reports and this whole Consultation process. It would be a massive blow! It’s upsetting me now as I write this.

Again in your documents much is said about the importance of open spaces, green spaces, wellbeing, but it just seems to be ignored.

Transport
Your Sustainability Appraisal Report rates SA4 as a Minor Positive, but it only considers rail, bus and cycling, and even then only in so far as the distance to the station, bus stop or cycle path. For example no consideration of what bus services use that stop or how often it runs. You hope to encourage sustainable transport, which is great, but let’s be realistic cars are going to be the main form of transport. There is no plan on how traffic would access the site or how to accommodate increased traffic flow. For the 10256 site area would you dump all the traffic straight onto St John’s Road, or split it with the A137/Parsons Heath? St John’s Road suffers from high congestion at peak times and vehicle numbers are increasing all the time anyway. I found some survey figures about daily traffic flow on the Gov.uk site done by the Department for Transport. In 2009 it was 10264 vehicles and in 2019 it was 17259, a 68% increase! Traffic from the 10616 site would presumably exit onto the A137/Parsons Heath, and or Bromley Rd, not forgetting this site is split by the railway, so a new bridge or tunnel would have to be built. The whole Parsons Heath/Harwich Rd/Bromley Rd/St John’s Rd traffic system isn’t able to cope with a significant rise in traffic flow, it would just be misery.

Services
My main concern is healthcare shortfall if development went ahead. I have two elderly relatives living on St John’s and have a chronic health condition myself. The local surgery, Parson’s Heath Medical Practice, is severely stretched, and I have been told that it isn’t accepting new patients. Also Colchester General Hospital is at or beyond capacity. How is this to be resolved?

Urban Spread
The Tendring Colchester Borders Garden Community is to provide 7500 homes, although at a glacially slow pace as far as I can see (3400 homes by 2041 and completion in 30 years?). I thought the selling point of this was to stop further building in the area, but PP9 would be barely separated from it adding another 2000 homes. A large part of north east Colchester would go from countryside to residential. PP9 goes right up to the edge of the City boundary, so you have no control on what would border it, meaning extra housing could be built to the north of it stretching towards Ardleigh.

Water
Obviously water supply in the area is a major concern. The Environment Agency says the area is “under severe water stress”. Colchester Infrastructure Audit and Delivery Plan Stage 3 predicted a deficit for Essex South WRZ in 2025! Waste water treatment currently only has capacity until 2031, with no identified growth plan. As already mentioned I note that surface water is to be stored on site, but I still have concerns about future flooding without careful planning. Bullace Close seems to be an example of what happens when this isn’t done. A long time ago, before construction, this was an unsurfaced lane with a field side ditch. When houses and a road were built the ditch was filled in, so now after heavy rainfall the end of the road turns into a pond. However my major concern is that in controlling and channeling drainage from what would have been fields around Bullock Woods, the natural gradual flow of groundwater from the fields that the woods rely on will be lost thereby drying out and damaging the woods.

Infrastructure Funding
The Colchester Infrastructure Audit and Delivery Plan Stage 3 Report shows a significant funding gap. (6.2.4.) “Total costs of £1,318 million and funding of £506 million have been identified. This implies a funding gap of £811 million. 168 of the 230 line entries in the Project Schedule have costs against them.” Basically you can’t identify where the money to pay for the things that make the whole Local Plan viable will come from. The danger being that necessary infrastructure won’t actually get built.

Summary
There is so much more that that could be said, but I know that a full Report has been submitted by the St John’s Residents Association objecting to the inclusion of St John’s Fields in Policy PP9, so will refer you to that. Basically looking through this whole Consultation I read so many good things. I have commented on lots of the Policies, but didn’t feel the need to object to many of them, so I urge you to think again and properly apply what is in the Policies. Thank you.

I object to build house's on our lovely fields!is exactly opposite of my hosue and our road is always traffic in the morning(school time)and afternoon to!I have 2 dog's and we are every day ln the field, is the safest place to walk around with them!please don't take this from us!our walks is helps me to,to clear my head after a long day work, is relaxing and healthy fresh air for every day!we moved from London. This place is our dream place amd home

PP9: North East Colchester
    Site IDs: 10616, 10616a and 10616b

Traffic congestion is already problematic without making things worse.
Loss of countryside.

We therefore object to the development.

Dear Sir/Madam,
I am writing to register my strong objection to the proposed development PP9 North Colchester. The application raises significant environmental, infrastructural, and community‑impact concerns that cannot be mitigated and would result in long‑term harm to the area.
1. Irreversible Harm to Bullock Woods (SSSI)
Bullock Woods is a designated Site of Special Scientific Interest and an ancient woodland that relies on a delicate and highly specific drainage system. Any construction in close proximity threatens this system and risks irreversible ecological damage. There is no viable mitigation strategy that would prevent harm to this protected habitat.
2. Degradation of Local Landscape, Ecology, and Heritage
The proposed development would permanently alter the character of the surrounding landscape. The ecological and heritage value of this area cannot be replaced or offset, and the loss would be felt across the wider community and natural environment.
3. Loss of an Essential Green Corridor
The site forms part of a vital green corridor that supports wildlife movement, breeding, and long‑term survival. Fragmenting or removing this corridor would have a severe negative impact on biodiversity and local species resilience.
4. Loss of Vital Green Space for Residents’ Wellbeing
Access to natural green spaces is widely recognised as essential for mental health, stress reduction, and overall wellbeing. This area is one of the few accessible natural environments available to many local residents. Its removal would significantly reduce opportunities for walking, relaxation, and community connection, undermining public health and quality of life.
5. Increased Flood Risk Due to Loss of Natural Drainage
Bullace Close, which borders one of the fields under consideration, already experiences consistent flooding. Additional housing would reduce natural permeable land, further restricting drainage capacity and worsening an existing and well‑documented problem for residents.
6. Insufficient Infrastructure and an Unsuitable Road Network
There is no committed funding for the substantial road improvements that would be required to support this development. St John’s Road, the primary route from the proposed site, is already heavily congested on a daily basis. It is a residential street and wholly unsuitable as a main corridor to the A12, yet this would become unavoidable if development proceeds.
Furthermore, water pressure in the area is already very poor and additional housing would place further strain on a system that is already struggling to meet current demand.
7. Increased Pressure on Public Services
Local healthcare and education services are already operating under significant strain. Additional population growth would further reduce access to essential services and negatively affect service quality for existing residents.

Conclusion
For the reasons outlined above, the proposed development would cause substantial and irreversible harm to the environment, local infrastructure, and community wellbeing. The site is fundamentally unsuitable for development, and I respectfully request that the application be refused.
Thank you for considering my objection.

I live in the St Johns area and use the fields to walk my dogs daily, along with many others! It would be such a shame to lose such a lovely green space which a lot of local people enjoy all year round. Traffic in and around Colchester is bad enough even without the addition of 2000 new dwellings, and I think a change like this could potentially cause a lot of people to move out the area which would be a shame considering many people in this area have been there for many many years.

PP9: North East Colchester
Site IDs: 10616, 10616a and 10616b


As I have not been able to do so via other means due to the time lag in receiving my registration code, I am now writing to you directly.

Along with many of my neighbours, I am raising my objection to this proposed development - it’s not just the despoiling the beautiful agriculturally landscape of the valley but also its likely impact on local wildlife Here is a recent photo from my back garden:
(Picture of fox embedded into email )
not sure Colchester Cares

We object to this proposal for the following reasons:
Over subscribed GPSurgery, schools and hospital, none of which would cope with so many additional residents in the area
Traffic congestion, lack of travel infrastructure to deal with additional traffic
Detrimental affect on wildlife in Bullock wood
Loss of open space and farmland for food production
Noise disturbance during construction
Disruption to Daily life of residents who(like us) specifically moved to this area because of the open spaces
Affect on property prices
Lacksof amenities in the area to support additional residents
Pressure on water supply
Risk of flooding

I would like to register my OBJECTION to the inclusion of the above site within the Council’s current Draft Local Plan, based upon the following considerations:-

1) Lack of Infrastructure. As highlighted at the first of the Local Plan Council meetings that I attended late last year, there is currently NO additional funding for the roads that would require to be built as a result of this huge development. The Council are only too well aware that traffic around North East Colchester is already severely stressed, and a development of the magnitude proposed (2,000 houses) would only lead to even more gridlocking: residents of the St. John’s area are rightly very concerned about future traffic impact and their ability to be able to move around the City. There is of course, added concern for the inevitably negative impacts upon healthcare and school service provision.

2) Loss of valuable community space for residents. The fields and pathways adjacent to Bullock Wood are used extensively by residents, locals & dog walkers for their health and well-being: recalling as recently as the Covid outbreaks the importance placed by both central & local government representatives on the importance of ‘green space’ for local populations. Indeed, it is incredulous that against a back drop of an administration espousing a ‘brown field first’ mantra as recently as 2024 as part of their pre-election pledge for the new housing allocation numbers, we now appear to be seeking to compromise the very same ‘green space’ upon which our local residents are dependent. Furthermore, Council will be only too aware that this area (and others currently within the Draft Local Plan) are included within their VERY OWN ‘Colchester Orbital’ walking publication, a document, to quote, “connecting some of our loveliest and most important (my italics) green spaces”. For the Council to now perform a complete volte face and cynically seek to include these areas within the Local Plan is simply unforgivable.

3) Environmental Impact. A development of the size proposed would irreparably damage the ecology, biodiversity and local landscape of the area. As with ‘Middlewick’, this whole area is most important (Council’s words) in terms of its natural heritage, working as the essential ‘green corridor’ linking wildlife habitats across the area. Council are already aware that any loss of supporting land would have a detrimental effect upon Bullock Wood, already a Site of Special Scientific Interest (SSSI), in relation to existing drainage upon which the woodland depends. The wilful compromise of an SSSI along with the loss of adjacent prime agricultural production land runs completely contrary to the Government’s very own overtures on both Biodiversity Net Gain (BNG) AND the need to protect future UK food security.

In short, and for the reasons outlined above, this is EXACTLY the type of area that should be protected from further development, and the Local Plan must more correctly give preference to the inclusion of existing use/low grade/brown field land within the Draft.

Graham White

I object to the proposal of 2000 homes in North East Colchester for the following reasons:

There will be inadequate availability at GP surgeries, dentist and hospitals. Local schools are already oversubscribed. The traffic in St Johns Road is constantly gridlocked, even outside of rush hour. The roads are damaged already without the additional traffic. There are already plans for 9,000 homes at TCBGC and the infrastructure cannot take another project. Bullock Wood SSSI and impact. Loss of green corridor and impact on wildlife, habitat, trees and residents with an increased risk of flooding.

Development in Welshwood Valley, site ID:10616, 10616a, 10616b, will impact on local amenities, due to inadequate road infrastructure, inadequate Primary and Secondary Healthcare provision for ‘approximate’ 2000 homes. The population will be approximately double or more in number. Eco and biodiversity will be greatly negatively impacted.
Bus Routes are limited.
Narrow roads are already clogged with heavy traffic.
Water scarcity especially in the hotter months are a serious concern

I am writing to submit my strong objection to the proposed development at PP9 North Colchester. The application presents significant environmental, infrastructure, and community impacts that cannot be mitigated and would result in lasting harm to the area.
1. Irreversible Damage to Bullock Woods (SSSI)
Bullock Woods is an ancient woodland and formally designated Site of Special Scientific Interest. Its survival depends on a fragile and highly specific natural drainage system. Any construction nearby poses a serious risk of disrupting this hydrology, resulting in irreversible ecological damage. There is no feasible mitigation strategy capable of protecting this sensitive and legally protected habitat.
2. Harm to Local Landscape, Ecology, and Heritage
The development would fundamentally and permanently alter the surrounding landscape. The ecological value and heritage significance of this area cannot be replaced, recreated, or offset. The loss would be detrimental both to the natural environment and to the character of the wider community.
3. Loss of an Essential Wildlife Corridor
The site forms part of a crucial green corridor that supports wildlife movement, breeding, and resilience. Fragmenting or removing this corridor would severely impact biodiversity, threatening the long term survival of local species that rely on connected habitats.
4. Removal of Important Green Space for Residents’ Wellbeing
Accessible natural green space is essential for mental and physical wellbeing. This area offers valuable opportunities for walking, relaxation, and enjoying nature, particularly for residents with limited access to outdoor environments. Its loss would significantly reduce local community wellbeing and quality of life.
5. Increased Flood Risk Due to Reduced Natural Drainage
Residents of Bullace Close already experience recurring flooding. Developing on land that currently helps absorb surface water will reduce natural permeability and aggravate an existing and well documented drainage problem. This poses a direct risk to nearby homes and infrastructure.
6. Inadequate Infrastructure and Unsuitable Road Network
There is no secured funding for the substantial road upgrades required to support this development. St John’s Road—the primary route from the site—is already heavily congested and unsuitable for the increased traffic volumes that would result. It is a residential street and not designed to function as the main access route to the A12.
In addition, water pressure in the area is already low. Further housing would place additional strain on a system that is currently unable to meet existing demand.
7. Additional Pressure on Local Public Services
Healthcare and education services in the area are under significant pressure, with limited capacity to accommodate further population growth. This development would exacerbate existing shortages and reduce access to essential services for current residents.

Please refer to accompanying Statement

I am very concerned with the effect that the development off Bromley Road will have on amenities and traffic. The Bromley Road is very heavily used and gets very congested on the stretch from the junction with Longridge to the junction with the A137 at Parsons Heath. The A137 is also very busy leading to further congestion along the entire length of St John's Road. St John's Road and the Bromley Road were not designed for the current high volumes of traffic accessing the railway station. Two thousand more homes, many of whom will be occupied by one or more London cimuters will bring traffic in this area to a complete standstill. The Bromley Road carries school traffic to the Sir Charles Lucas Academy as well as junior schools and a well-used local Tesco store. The extra traffic from the developments 10616, 10616a and 10616b will gridlock these three roads.
Where will these new residents or their children in due course find jobs in Colchester? Commuting is of course a solution but the proposed development is the worst part of Colchester from which to commute by train. Once more the roads will take a pounding and there is little scope for developing the transport infrastructure.
Parsons Heath Surgery do a magnificant job in providing healthcare in the area but an influx of 8,000 extra residents would be the straw to break the camel's back.
My children are well past school age but going back thirty years, both the local primary schools were oversubscribed then. I can only imagine the effectthese developments will have.
Welshwood and the footpath system around the area play a vital role in recreation in the area. Their loss would would be to the detriment of all residents. There are no local playing fields or other recreational facilities and this wouldlead to more car traffic to access leisure facilities in other parts of the town.

I do not agree with this proposal due to the following reasons:
This open space is the only open space that is accessible to residents living in North East Colchester. (The only other recreational land is Highwoods).
The local infrastructure would not be able to cope with the increased number of residents which brings:
Increase in traffic (traffic along st Johns road/Ipswich Rd is already very congested especially at peak times)
Local doctor surgeries are already dealing with extra patients from the northern gateway developments, more residents in the St Johns area will put an increase pressure on local NHS services.
Question? Is there capacity at local schools?
Nature will be affected..loss of homes

With regard to draft policy PP9: North East Colchester, Latimer must currently object to the allocation on transport capacity grounds. Latimer consider that the potential highways impact of PP9 has not been properly and robustly assessed within the transport evidence base. It is considered that insufficient evidence has been provided to demonstrate the deliverability of this c.2,000 home allocation from a highways and transport perspective, given the existing commitments associated with the build-out of the TCBGC.

It is essential that the existing commitment to prioritising the committed TCBGC is maintained and not prejudiced by future development and that the deliverability of the proposed PP9 allocation is suitably evidenced, based on detailed analysis of potential access points and highway capacity considerations of the local area, based on robust evidence.

The attached ‘Review of Local Plan Regulation 18 Consultation Transport Evidence Base’ Technical Note, prepared by Stantec (Appendix 1) sets out the basis for the highway concerns that Latimer have, along with some interrelated issues identified from the transport evidence submitted in support of the emerging Local Plan.

The Technical Note concludes that in its current form, the transport evidence base (Transport Evidence dated February 2025 and the Further Transport Evidence dated October 2025) supporting the preferred option allocations set out in Local Plan Regulation 18 Consultation is unsound due to a number of issues, specifically:
• Whilst the evidence considers the delivery of 3,650 homes at TCBGC, the evidence fails to consider any development within the Crockleford Neighbourhood (up to 1,500 homes) being delivered up to 2041. In reality, almost all development within the Crockleford Neighbourhood (which will include a school and a village centre), will be delivered. This Neighbourhood relies on sole access via the existing Bromley Road (owing to Vehicle Access Zone policies within the DPD) and relies on the same wider highway infrastructure as the draft Policy PP9 allocation.
• The proposed wording of Policy PP9: North East Colchester does not provide any clarity on the requirements for the access strategy for the allocation. Therefore, the impact of this proposed allocation on areas of the highway network, which are likely to experience capacity issues under existing or future committed conditions, cannot be, and has not been, fully assessed or understood.
• A high level review of the potential vehicular impact of the PP9: North East Colchester allocation, indicates that it will have a significant impact on the Bromley Road corridor and wider Harwich Road/Parsons Heath highways infrastructure, which is anticipated to be subject to highway capacity constraints in future years. As the Crockleford Neighbourhood area of the TCBGC will also be accessed via Bromley Road, it is considered that insufficient assessment has been undertaken to demonstrate that the proposed allocation will be deliverable in its current form alongside TCBGC as a committed development. Other concerns in relation to the clarity and accuracy of the assessment of the proposed allocation’s impact have also been identified.
• The 2041 Reference Case against which the impact of the various proposed allocation scenarios is benchmarked, only accounts for a small proportion of the TCBGC traffic development, all of which appears to be accessed via the A1331 which does not accord with Latimer’s phasing or delivery of the TCBGC site. The PP9: North East Colchester allocation has the potential to take-up highway capacity which is required for the committed Crockleford Neighbourhood. The deliverability of the PP9 allocation is therefore in question and could prejudice the development of the committed Garden Community.
• Assumptions made in Further Transport Evidence relating to improvements to the Greenstead Roundabout, Colne Causeway and A12 Junction 29 being delivered solely as mitigation for TCBGC and therefore included in the 2041 Reference Case are contradicted by the IADP. The associated Project Schedule indicates that the majority of these schemes will be at least partially funded by the preferred allocations which raises serious questions about the accuracy of a reference case (which includes these improvements as mitigation for the TCBGC) against which to test the impact of the preferred allocations.
To rectify these issues and ensure that the Local Plan Regulation 18 Consultation is supported by an accurate, robust and transparent transport evidence the following is requested:
• Provision of additional clarity on the assessment of the proposed PP9: North East Colchester allocation, the constraints identified, the assumptions applied in relation to access points and the forecast vehicle trips generated under the various scenarios tested in Further Transport Evidence.
• Revision of the 2041 Reference Case used to test the impact of the proposed allocation to include an assumption that TCBGC is delivered in full, reflecting it as an allocated and committed project. TCBGC must be fully considered and prioritised and the highway capacity on the network required to accommodate this is reserved and fully considered from the outset.
• Clarification of the assumptions informing the infrastructure improvements to be delivered within the 2041 Reference Case to enable determination of whether these accurately reflect what will be delivered by TCGBC and the preferred allocations respectively so that only infrastructure which will be in place to mitigate the future baseline development is included within the reference case scenarios.
• Retesting of the impact of the PP9: North East Colchester allocation against the revised 2041 reference case to establish whether its cumulative impact (in addition to the full TCBGC and with the appropriate assumptions relating to highway infrastructure applied) allows Bromley Road and the wider highway network to operate acceptably following the various accompanying sustainable transport and highway infrastructure improvements and measures considered within Further Transport Evidence.
• Further highway rearrangements may need to be considered which would be contrary to current adopted DPD policy. For example, providing vehicular access from the Ardleigh end of Bromley Road onto the new A1331/A120 junction, potentially through the draft employment allocation in TDC’s emerging Local Plan.

If these actions are not taken, the potential impacts of the delivery of c.9,500 homes in North-East Colchester will not have been fully considered and could result in a severe impact on the highway network, even in a Vision-led scenario, which would be contrary to the NPPF. It is therefore critical that the assumptions informing draft Policy PP9 be reviewed to ascertain whether both the committed TCBGC and proposed PP9 allocation can both be accommodated.

Objection to the Inclusion of Site PP9 in the Local Plan

I can't go into detail about all the various policies and regulations, so I will just talk about my concerns and fears about the possible large scale development the fields bordering St John's Estate.

As a bit of background I moved to the Estate in 1966 with my family and ran the butchers shop in St Christopher Rd with my father and mother until 1990. I'm 89 years old and have a sister also on the Estate, along with one of my son's. Therefore I have a long and close bond to the area.

I'm not steady enough on my feet now to walk at the fields, but they are still important to me. My sons played there as children and I like to think that contributed to their lifelong interest in nature and conserving it. It is so important that children have aesy access to the countryside, particularly nowdays when they seem to spend so much time inside staring at a small screen. It would be very upsetting to think that my grandchildren could lose this space to explore and learn about nature in.

As I said I'm pretty ancient now and my sister isn't a lot younger, we both want to know that we have easy access to local healthcare. I'm worried that this would be adversely affected if there was a great increase in the size of the Estate.

I'm also worried about the increase in traffic extra housing would bring. I'm told that there is no plan to improve the road network to cope with any increase. St John's Rd is very busy and I'm concerned that extra congestion there will lead to more cars using St Cyrus Rd as a sort of rat run, as this is close to where I live. I already consider it a dangerous road, particularly at school pick-up and drop-off times, with pavements blocked due to parked cars and poor visability. This is dangerous for us old ones as we can't move quickly and don't want to have to squeeze past badly parked cars.

Thank you for your consideration.

I am writing to place an objection to the proposed development of 2000 homes at St John's fields & Welshwood.
As a resident of St John's I cannot see how our current infrastructure would cope. St John's road, Parsons Heath, Ipswich Road and surrounding areas are already highly congested with traffic. Extra traffic will have a knock on effect on other roads, as well as contributing to local pollution.
Our Doctors surgeries are already struggling with demand, without extra patients. How will the local authority deal with this?
Of course there is the detrimental effect it will have on local wildlife. Bullock wood SSSI would dry out if proposed drainage of the fields takes place. Wildlife corridors along the fields to the wood will be lost. People love to use these fields to walk, be in nature, take their Dog & find a little peace within a busy area.
Therefore I see no gain to our community in this housing development. Only great losses that we will not be able to get back.

I am the retained Land Agent for the [REDACTED FAMILY NAME] and am instructed to submit this representation on their behalf. The Family control land at Shaw's Farm, Parsons Heath, Colchester, which forms a part of the draft housing allocation under Policy PP9 (North-East Colchester) for approximately 2,000 dwellings.

Site Description

The site amounts to approximately 12.4 ha of agricultural land situated to the north-east of Colchester, as shown on the attached location plan. Part of the site (circa 3.8 ha) to its north­ east extends beyond the administrative boundary of Colchester City Council.

It is bound to the north by further agricultural fields; to the east by land north of Bromley Road which also forms part of the draft housing allocation; to the south by the existing housing at Welshwood Park; and to the west by Great Eastern Main Line.

The site comprises several residential and agricultural buildings. Access is currently served by a single-track adjoining Harwich Road (A137) providing direct access to the buildings and wider lane. Several Public Rights of Way extend across the site providing connectivity to the north, south and west: Footpath 44, 111, 114 and 115.
It is unconstrained by any statutory or non-statutory planning policy designations.

Draft Policy PP9
We support the principle of draft Policy PP9 which seeks to allocate approximately 2,000 dwellings at North-East Colchester. We understand the site forms part of the wider allocation and recognise the importance of collaborating with the other parties in order to bring forward a comprehensive development.

We therefore consider the site is deliverable as it is available for housing now, a suitable location for development and achievable with a realistic prospect that housing will be delivered on the site within five years.
We are happy to engage in further discussion regarding the site should the Council wish to discuss this further.

These representations have been prepared by Boyer on behalf of [NAME REDACTED] in response to the Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025.
The purpose of these representations is to assist Colchester City Council ('the Council') in formulating an approach within the emerging Local Plan that is both consistent with national planning policy and the tests of soundness.
At this early stage of plan-making, it is important that the Council pursues an approach that is consistent with national policy, effective, justified, and positively prepared, in order for the Local Plan to be found sound at examination. These representations comprise our recommendations to assist the Council in achieving such an approach as the emerging plan progresses toward adoption.
The representations relate to the property known as Crockleford Mill, located off Bromley Road, to the north east of Colchester and seek to protect the Mill and its environs as a result of proposed policies in the emerging Local Plan.

Our comments on certain proposed policies in the Plan are set out below.

Policy ST2: Environment and the Green Network and Waterways

We agree with the general principle of this policy that proposals should conserve and enhance Colchester's natural and historic environment and encourage proposals to deliver high quality open spaces. It is important that ecology and biodiversity across the Plan area is protected and where possible enhanced.
The policy seeks to identify strategic biodiversity areas which are presented on the proposals map, with the policy noting as follows:

"Strategic areas that present the best opportunities for habitat creation and enhancement aimed at improving biodiversity are shown on the policies maps as 'strategic biodiversity areas'. These strategic biodiversity areas will be protected, and support will be given to strengthening and enhancing connections between habitats to improve their contribution to the biodiversity network."

The emerging Local Plan evidence base includes the Colchester City Strategic Biodiversity Assessment (dated January 2025) which provides an assessment of the priorities for strategic promotion of biodiversity within the planning system focussed on the urban area of Colchester City. The intention is to highlight those areas in and around the city in which biodiversity enhancement and creation would provide the greatest benefits.
Salary Brook is identified as an area of biodiversity significance within the report, which is carried through into the Local Plan. Salary Brook flows through Ardleigh Reservoir and then down the eastern edge of the City, joining the River Colne near the University. The evidence base report notes that alongside the brook itself, there are areas of scrub, lowland fen and
marshy grassland in the lower sections, and a corridor of scrub and woodland lining the riverbanks further north. The report also notes that "parts of the area are publicly owned and heavily used by the local community, with management not entirely beneficial to biodiversity, leading to a spread of scrub over what was open grassland. There is the potential for enhancement of these areas by introducing management focused on nature conservation outcomes."
With regard to formal designations, the Salary Brook Local Nature Reserve (LNR) is the publicly owned area of the LoWS of the same name (Co146) and consists of the watercourse itself together with marshy grassland and fen communities, scrub and trees in the river corridor.
The Proposals Map identifies the strategic biodiversity area designation and shows that it covers the area along Salary Brook and includes within it the Crockleford Mill complex of buildings to the east as well as open land within our clients ownership to the west, as shown in the centre of the extract of the Proposals Map below.

From the Interactive Proposals Map, it appears that no other residential properties are included within the Salary Brook strategic biodiversity area. We recognise the importance of landscapes and open land being designated as being able to assist in the connection of fragmented habitats and enhancing the ecological network however, we question the merit of including buildings and garden space within this designation and it is unclear what impact this will have on the landowner in terms of future obligations.
In particular, paragraph 2.12 of the Colchester City Strategic Biodiversity Assessment notes that "Wherever possible, and appropriate to the biodiversity objectives, sites established or managed for the benefit of biodiversity should also be available to local communities, especially where this provides educational opportunities." The Crockleford Mill buildings and environs are in private ownership and is not a site established or managed for the benefit of biodiversity in the first
instance, nor is it available to local communities. The requirements of the strategic biodiversity area are unclear and appear to create additional obligations on the landowner and prohibitions above and beyond other residential sites in the locality.
We therefore request that the boundary of the strategic biodiversity area be amended to exclude the Crockleford Mill buildings and ownership. An ownership plan can be provided should this be required to assist with the redrawing of the boundary.

Policy PP9: North-East Colchester
The allocation to North-East Colchester proposes ''.4 predominantly residential development including community infrastructure, strategic open space and approximately 2,000 new dwellings." We acknowledge that significant infrastructure and mitigation requirements are set out within the policy as well as Policy ST7 which assist in ensuring the site and proposals properly consider its wider context and require appropriate infrastructure to address the quantum of development being proposed.
This proposed allocation lies immediately to the north and west of Crockleford Mill and its associated land to the east of the access lane, and we wish to make comment on a number of criteria within the policy to ensure appropriate protection of Crockleford Mill in terms of residential amenity as well as environmental considerations.
Firstly, it is clear that any information contained within Policy PP9 can only relate to land within the policy boundary and cannot apply to land outside of the boundary. It is not appropriate for the policy to restrict the use of land outside of the policy boundary. As currently worded some policy criteria seek buffers to areas outside of the policy boundary appear to place restrictions on the use of land outside of the policy boundary and in the vicinity of Crockleford Mill in the ownership of our client. Additional restrictions are not necessary as any development at Crockleford Mill and its associated land would be subject to its own assessment by the Local Planning Authority.
Secondly, the provision of an appropriate buffer of approximately 50m wide free of development abutting the southern boundary of the policy site, adjacent to the access lane would protect the setting of the existing Crockleford Mill for many reasons including residential amenity, visual impacts and noise impacts. The development of such a large allocation in a currently rural area on the edge of the city, alongside the existing commitment of the Tendring Colchester Borders Garden Community (TCBGC) to the east will significantly change the appearance of this part of Colchester City and it is essential that existing properties are respected and protected for their own value.
It is welcomed that the policy requires a site masterplan to be prepared for the allocation area and it is imperative that this is to be undertaken through engagement with the local community ensuring local residents have adequate opportunity to comment and ensure appropriate protection is afforded to neighbouring dwellings.
Policy PP9 would therefore benefit from further clarity on the extent of the buffers to Salary Brook for it to be considered effective.
The purpose of these representations has been to assist Colchester City Council in formulating an approach within the emerging Local Plan that is both consistent with national planning policy and the tests on soundness.
In this regard, our representations relate to the tests of soundness set out at paragraph 36 of the National Planning Policy Framework ('NPPF') (2024); namely, whether the emerging Local Plan is: Positively prepared; Justified; Effective; and Consistent with national policy.
In conclusion, these representations suggest some amendments to the Plan to ensure it is positively prepared and effective in its policies and justifications.

I am writing as a local resident to formally object to the proposed housing development at PP9 North East Colchester, St John’s Fields / Welshwood.

My objection is based on the following concerns:

Loss of greenfield land
The proposed development would result in the permanent loss of valued greenfield land. This area currently provides important open space and contributes to the character of the local environment. Once developed, this land cannot be replaced, and its loss would set a concerning precedent for further encroachment onto undeveloped areas.

Impact on wildlife and habitats
St John’s Fields / Welshwood supports local wildlife and forms part of a wider network of green spaces. Development on this site risks disrupting habitats, reducing biodiversity, and harming species that rely on this land for shelter and foraging. I am concerned that any mitigation proposed would be insufficient to compensate for this loss.

Increased traffic and lack of infrastructure
The local road network is already under significant pressure, particularly during peak hours. Additional housing in this location would inevitably lead to increased traffic congestion, noise, and air pollution. Furthermore, existing infrastructure — including roads, public transport, schools, and healthcare services — is already stretched and does not appear capable of accommodating the additional demand created by this development. I personally notice this on a daily basis on my commute to the station.

Taken together, these issues suggest that the proposed development is not sustainable and would have a negative impact on both the environment and the quality of life for existing residents. I respectfully request that the council gives full consideration to these concerns and rejects the proposal.

Thank you for considering my comments.

Yours faithfully,

Mr Thomas Pitt

l. INTRODUCTION

1.1 This letter comprises a representation to the Colchester Local Plan Review Regulation 18 consultation. It has been prepared by Ceres Property on behalf of Gleeson Land - the promoters of land north of Bromley Lane, North East Colchester.
1.2 The land the subject of this representation is outlined in red on the accompanying plan (Ref: 410_067310) (Appendix A). It comprises 46.62 ha (of which 41.74 ha falls within Colchester City Council) situated within a wider area of land proposed for allocation in the Regulation 18 Preferred Options Local Plan under Policy PP9. This representation relates to the land under Gleeson Land's control only, but has been informed by work being undertaken regarding the wider land allocation alongside.

1.3 Gleeson are working alongside Gladman, who are the other party with a major land interest in the allocation, to prepare a cohesive masterplan for the site as a whole.This would support the progress of individual planning applications without risk to the overall objectives of the allocation as a whole. The latest version of the respective Masterplan Framework (Appendix B) is appended to this representation.
1.4 You will note they support and have directly informed the proposals for the land the subject of this representation.

1.5 Despite the above, the 46.62 ha being promoted by Gleeson Land remains deliverable in its own right, as detailed later in this representation.
1.6 In preparing these representations, regard has been had for Chapter 3 of the National Planning Policy Framework (NPPF) which relates to 'plan-making'.

1.7 Paragraph 15 of the NPPF promotes a plan-led system, and that succinct and up-to-date plans should provide a positive vision for the future of each area; a framework for addressing housing needs and other economic, social and environmental policies; and a platform for local people to shape their surroundings.
1.8 Paragraph 16 states that Plans should:

a) be prepared with the objective of contributing to the achievement of sustainable development;

b) be prepared positively, in a way that is aspirational but deliverable;

c) be shaped by early, proportionate and effective engagement between plan- makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

e) be accessible through the use of digital tools to assist public involvement and policy presentation; and

f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).
1.9 As set out at paragraph 36, local plans are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are 'sound'. The test for soundness as set out within the NPPF requires that Plans are:

a) Positively prepared

b) Justified

c) Effective

d) Consistent with national policy

1.10 By way of background to the Council's preparation of the emerging Local Plan, it is acknowledged that the Council's current five year land supply is increasingly marginal.
1.11 In February 2026 the existing Adopted Section 1 Local Plan becomes 5 years old, and the housing requirement within it will accordingly be out of date for the purposes of calculation of five year housing land supply as set by NPPF paragraph 232.

1.12 The housing land supply annual requirement will therefore become approximately 1,300 homes per annum in line with the standard method, as opposed to 920 homes per annum within the existing adopted Local Plan. Over a five year period this will add 1,900 homes to the required supply plus the required buffer.
1.13 The Council acknowledge this requirement at paragraph 3.36 of the Regulation 18 Consultation document, confirming that the requirement for 20,800 new homes over the plan period is a mandatory target which must be planned for. Taking into account the homes to be delivered through the Tendring Colchester Borders Garden Community and windfall sites, the Council assert at paragraph 3.40 the need to plan for a minimum of 11,089 in order to meet the housing needs of Colchester (emphasis added).

2. THE SITE

2.1 The Site currently comprises cultivated agricultural land, split into four distinct parcels divided by hedgerows/field boundaries. There are existing minor power lines crossing the site approximately north to south, and east to west. These are shown on the accompanying Opportunities and Constraints Plan. There is also a gas main running north to the south through the site.
2.2 The eastern boundary of the site is defined by Salary Brook, with some small areas at risk offloading in association with this. Salary Brook also demarcates the authoritative boundary between Colchester City and Tendring District. To the north, the site meets further agricultural land. To the west/northwest the site meets existing residential development accessed from Welshwood Park Road and Woodlands, and additional land proposed for allocation towards the A137. An area of ancient woodland (Welsh Wood) insets the site in the eastern corner and then the southern extent of the site meets Bromley Road and Salary Close.

2.3 There are no listed buildings within direct proximity of the Site. The closest are Grade II Listed Hill Farmhouse and surrounding buildings which are south of Bromley Road and separated from the site by existing Salary Brook, existing vegetation and existing development along Bromley Road.
2.4 Due to its consistent use as an agricultural field, the ecological baseline of the Site is low. Despite this, the ecological value of the vegetated field and site boundaries should not be understated, and will therefore be duly considered for protection and enhancement as part of any future development proposals.
2.5 The Site is predominantly located within EA Flood Zone 1 (land at least risk of tidal and fluvial flooding), though some land area along the southeastern border are within Flood Zone 3, as well as being at risk of surface water flooding too.
2.6 More generally, the suitability of the site as a location for growth, and specifically for that of a significant scale, has already been recognised by the Council through its proposed allocation under Policy PP9.
2.7 The land adjoins the urban area of Colchester City and bus stops along Bromley Road provide regular bus services to the Hythe where there is a railway station, supermarkets and other retail and employment opportunities, Colchester town centre (including stops close to North Station), and through to Stanway too where there are a number of additional retail and leisure facilities. More local facilities are just a short walk (approx. 400m) from the site along Bromley Road, including a local conveniences store, a nursery, Hazlemere Infant and Junior schools and Colchester Academy.
2.8 The site's constraints and opportunities have been mapped on the accompanying plan prepared by FPCR. Existing utilities routes are easily managed through rerouting and grounding, and the overall extent of the site affords ample land for the protection of a buffer for the adjacent ancient woodland to the west, as well as the avoidance of development in areas at risk of flooding which in turn provides an opportunity for the extension and enhancement of the Strategic Biodiversity Area alongside the adjacent watercourse along the southern boundary. Existing public rights of way through and around the site are also considered as opportunities for enhanced site access and connectivity. There are therefore no significant physical constraints to the sites development.

2.9 Some specific site constraints and opportunities have been considered in more detail below.

Access and Public Rights of Way

2.10 Engagement with Essex Highways has confirmed a scope and design for an access which would be suitable for the proposed development. The site would require a single access only, and is proposed to be taken from Bromley Road. Onward connectivity into surrounding areas and the rest of the proposed allocation will be in the form of pedestrian and cycle connections only.
2.11 Public Footpath 113 dissects the Site but is well-positioned to be retained and incorporated into future proposals to retain and enhance onward connectivity from the site to surrounding development and countryside to the northwest and southeast. The proposals will also provide opportunities for connection into Footpath 114 which runs along the northeastern boundary.

Arboriculture

2.12 There are no Tree Protection Orders on the site itself, but Welsh Wood Ancient Woodland meets the site in the southwestern corner. There is a requirement for an overall buffer for this woodland, as well as for the closest individual veteran trees within it. These have been set at fixed constraints from the outset. A Preliminary Arboricultural Appraisal identified a number of other high quality trees along the existing field boundaries, and along Bromley Road. These have been highlighted on the accompanying Constraints and Opportunities Plan and tree retention in these areas will be a priority.
Ecology

2.13 A preliminary ecological appraisal has also been undertaken for the site. The appraisal highlights that the Site is of the nature that would allow for a number of animal species to be supported.

Though further survey work would therefore be required as part of any future application, the early proposals have been designed to consider the existing value of the site, as well as the opportunities for maximising Biodiversity Net Gain and habitat opportunities alongside future development. The siting of the site along Salary Brook presents a unique opportunity in this respect.
Flood Risk

2.14 Areas of flood risk are limited to the boundary of the site along Salary Brook. An area of surface water flooding also runs along the internal field boundary and associated ditch. These areas have been excluded from proposed development areas and will instead be used for open space, drainage mitigation and ecological enhancement areas.
2.1 s The Council has of course undertaken a Sequential Test for all proposed allocations and this forms part of the Local Plan Evidence Base. This assessment confirms that only very small proportions of
the allocation are in areas of risk, and acknowledges that the requirement for an initial masterplan will ensure that development is kept outside of these areas of risk. It is on this basis that the site "passes" the Council's test.


3. POLICY ST3: Spatial Strategy

3.1 Gleeson Land support the Council's spatial strategy, which seeks to direct growth to the most sustainable and accessible locations in the urban area. Prioritising these locations, whilst of course supplemented by smaller allocations across lower order settlements, is inevitably a sustainable strategy in that it ensures development will be delivered in the most accessible locations, and where there is already an established principle of development in the immediately surrounding area.

3.2 Land at Bromley Road, as allocated through Policy PP9, supports this strategy given its location on the edge of the existing Colchester Urban Area, and in a highly accessible location.


4. POLICY PP9: North-East Colchester

4.1 Policy PP9 sets out a number of objectives for the wider site allocation, and thus it is important that any development of the smaller parcel the subject of this representation supports these objectives.

4.2 The policy recognises the importance of an overarching masterplan in ensuring that any phased development contributes to the overall objectives, and ensures that all are fully achieved across the allocation as a whole. Gleeson Land are working closely with other developers to prepare a masterplan, with the latest draft supporting this representation, with the expectation of formally submitting this to the Council for approval prior to the submission of any future planning applications. In the meantime however, in support of the promotion of this smaller parcel, each of the allocation objectives are considered in turn below.

The latest Development Framework considers that this part of the site could deliver around 750 homes across two main phases, based on a density of 35 dwellings per hectare and taking into account land reserved for landscaping, drainage and open space. When considered as part of the wider allocation, this is proportionate and supports the overall delivery intentions of the policy.

This representation is accompanied by an Access Appraisal and Transport Assessment Scoping Note which has been reviewed with Essex Highways through early pre-application discussions. We also provide a Pre-Application Response Note which follows up on the initial advice received. Most importantly, the engagement process has confirmed that a suitable single access can be achieved from Bromley Road for around 750 new homes.
The proposed access has been the subject of a Road Safety Audit too to provide further reassurance. Access opportunities for other parts of the allocation will be considered at the relevant time, but would be most appropriately accessed from Harwich Road and St John's Road, and thus independently of this part.


Proposals for active and sustainable travel will be developed through more detailed proposals and a full Transport Assessment, but pre-application discussions have identified an opportunity for a new Toucan crossing on Bromley Road to enhance pedestrian safety around this particular access point. Furthermore, the existing public rights of way are being considered as key opportunities within the Masterplan Framework of both this site and the wider allocation site, to ensure connectivity within the allocation as well as with surrounding land. The site is well-placed to access existing bus services.

At present, wider masterplan work has identified that the most suitable location for a local centre would be in the northwestern part of the allocation and the proposals for this more southerly part of the site would not hinder the delivery of this. Enhancements to existing public rights of way that cross the A12 would also ensure pedestrian and cycle connectivity to this centre from all parts of the allocation area.

At present, wider masterplan work has identified for a strategic open space would be most suitable in the northern part of the allocation. Nevertheless, the site the subject of this representation demonstrates appropriate space to provide open space to immediately serve homes in this part of the allocation, and contribute to the wider green network planned throughout area as a whole.

Detailed landscape proposals would be developed in due course, but the early Masterplan Framework ensures that a buffer is provided to Welsh Wood, and also to Salary Brook where it is proposed that this buffer could then in turn provide an opportunity for enhanced biodiversity and open space. Other early landscaping proposals include the retention and enhancement of existing landscape features along the field boundaries.

The site the subject of this representation does not meet Bullocks Wood. It does however neighbour Welsh Wood and an appropriate buffer will therefore be designed into proposals to ensure its protection.

An extensive buffer to the Salary Brook is proposed, and will provide generous space for its conservation and enhancement. The site drainage strategy will be carefully designed to manage the amount and quality of any surface water which may enter the existing watercourses.

Preliminary arboricultural assessments undertaken by Gleeson highlighted the key constraints in relation to the land under their control. This includes Welsh Wood Ancient Woodland and other trees and hedgerows of value within and around the site. These, with their associated buffers, have been set as fixed constraints to inform early site layout and land use proposals.

Extensive areas of open space are proposed on key site boundaries and will provide flexible spaces for planting and sensitive integration into the landscape.

Gleeson will be happy to work with other landowners and the Council to agree this. To date, key connectivity opportunities have been factored into early site design work.

Existing public rights of way within and around the site will be retained, and there may be opportunities for enhancement also. Furthermore, the site will be designed to encourage connectivity into these existing routes, and allow for permeability across the site and wider allocation as a whole.

Given the location of the designated heritage assets closest to this part of the site, it is expected that the proposals will be able to be designed in a manner which ensures that any harm to their wider settings is minimised and/or negated.

Gleeson will undertake this engagement as part of any future planning application.

Any future drainage strategy will consider this further.

This will be dealt with as part of any future planning application.

This will be considered through the development of a detailed drainage strategy for the site, and through design measures to minimise water consumption.

Gleeson are working with other parties with an interest across the allocation to ensure that land and space is reserved for such uses in the most suitable locations.

These surveys will be factored in the programme of species surveys that will be required prior to the determination of an application, as directed by Preliminary Ecological Appraisal work.

Gleeson are working with other parties in the preparation of a masterplan for the entire allocation area to meet this objective. The latest version of this document supports this representation and demonstrates the ability of the Site to complement the wider intentions of the allocation.

4.3 More generally, and whilst not a formal point of objection at this stage, we do consider it to be worth noting that there are a number of requirements within this policy which would ordinarily be addressed through standard development management policies set out elsewhere in the plan, and other national legislation. There may therefore be an opportunity to simplify the policy in areas.

5. POLICY GN5: Suitable Alternative Natural Greenspace

5.1 Proposed Policy GN5 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.

5.2 For site specific allocations, such as PP9, a provision of this nature, when taken with other land requirements set out through the policy, could have significant implications on viability.
5.3 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.

6. SUSTAINABILITY APPRAISAL

6.1 As part of this Regulation 18 Consultation, a Sustainability Appraisal Report has also been provided for review and comment. This latest report considers the site-specific policy text following earlier "policy-off' appraisals. This ensures that mitigation sought through the proposed policy wording is therefore now reflected in the assessment.
6.2 The majority of assessments remain the same, apart from Economic Growth which improves to a minor positive, from a minor negative. Biodiversity and geodiversity also improves to a minor negative from a significant negative. We support this further consideration of these site constraints.
6.3 Whilst the assessment remains unchanged, we continue to have concerns over the recording of a significant negative effect for the site in relation to SA objective 2 - Efficient use of land. This is based on the loss of greenfield land and Grade 2 and Grade 3 agricultural soils. The majority of agricultural land around Colchester is in fact Grade 2 or 3 and thus not considered a scarce resource. Additionally, some areas are Grade 1 and therefore it would be expected that development in these locations would be seen to have the most significant negative impact but there is no greater

6.4 Given that this would apply to the majority of allocations for the City, it is considered disproportionate to consider this as a significant negative effect and a categorisation as a minor negative effect would better reflect this constraint.

7. SUMMARY

7.1 Overall, Gleeson Land strongly support the proposed allocation of land north of Bromley Road. Whilst they do not control all land within the allocation, they are working closely with other landowners to ensure all of the objectives set out in Policy PP9 can be achieved.
7.2 More specifically, this representation has set out the extent to which their land can meet the objectives independently, and not hinder the delivery of the remainder of the allocation, emphasising the opportunity for new homes to be delivered over short timescales.

Please do not build 2000 homes on our treasured fields.
These fields have given my life so much more meaning. They are a part of my home, my well-being and my solace.
The area is such an important place for me, and to see its uniqueness carved up and punctuated with houses, as far as the eye can see, is truly upsetting.
The ground around the edges of Bullock Wood (area of SSSI) is already waterlogged after rainfall, as are the rear gardens on Evergreen Drive. Building more homes will exacerbate the issue as well as leading to the woods and the wildlife essentially dying due to draining changes, lighting and noise.
The traffic bottlenecks along St John’s Road and Ipswich Road are already well known. Cars are nose-to-tail along the entire stretch of these main artery roads every weekday morning and I can’t envisage anyone wanting to purchase their home in what is already such a heavily congested area.
Sewerage is another issue, especially as no definite plans are required before the development is approved. The Hythe sewerage works is already struggling with capacity issues and has reportedly exceeded capacity in some areas.
With this and other basic infrastructure requirements being neglected such as doctors & schools and the hospital also nearing maximum capacity, I believe the proposal to be a potential economic, societal and environmental disaster.