Scale too big for infrastructure.
Highways won’t cope.
Loss of greenery.
Impacts picturesque Birch Grove Golf Club.

I object to the proposed allocation of land south of Berechurch Hall Road for up to 875 dwellings under Policy PP10 for the following reasons:

1. Traffic and Highway Impact

The local road network, including Berechurch Hall Road and surrounding routes, already suffers from congestion. The scale of development proposed would generate a significant increase in traffic, leading to severe cumulative impacts that have not been adequately mitigated or justified.
The average household has 2 vehicles, this would equate to a potential 1600 extra cars to the area that is already overwhelmed.

2. Unsustainable Location

The site is poorly served by frequent public transport, meaning residents would be heavily reliant on private vehicles. This conflicts with sustainable development principles and objectives to reduce car dependency and carbon emissions.

3. Pressure on Infrastructure and Services

Local schools, GP surgeries and NHS services are already under strain. There is insufficient evidence that the infrastructure required to support an additional 875 dwellings would be delivered in a timely and effective manner. Local GP surgeries have periodically closed their books to attempt to manage the overwhelm of local people and still try to provide adequate care to patients.
The proposed dwellings will affect the adjoining golf clubs business.

4. Loss of Countryside and Character

The development would result in the loss of open countryside and contribute to urban sprawl, harming the character and appearance of the area and reducing separation between settlements.
With higher amounts of the population working from home, open spaces are needed for locals mental health and well being.

5. Flood Risk and Drainage

Development on this greenfield site risks increasing surface water runoff and flooding. Robust and detailed drainage solutions have not been clearly demonstrated.
The st Michael’s persimmon estate is already in struggling with insufficient drainage to the land causing issues to gardens and structures. It would be irresponsible to build further housing without these important issues being resolved.
6. Scale of Development

The size of the proposed allocation is disproportionate for this location and would place an excessive burden on south Colchester when considered alongside other planned developments.

There is mention of walking and cycling routes but these should be multi-user routes, to include horse riders. (This applies elsewhere as well.)

I strongly object to the proposed policy PP10, due to the detrimental effect this has on not only the existing residents, the natural environment, the lack of infrastructure but also the proposed new residents that would occupy this proposed development.

The proposed development is completely disproportionate to the current surrounding area. The new estate on Berechurch Hall Road (St Michaels Place), was only narrowly given the go ahead in 2021 and has only just been completed, with many houses still not sold on the development, so how is it necessary for a development 6.5 times its size required in the area. Not only that, it is proposed that the only access in and out of the policy proposal is through the new estate, which has not been built with the consideration of at least another 1600 vehicles passing through it onto Berechurch Hall Road. Not only that, but Berechurch Hall Road, is one of the most dangerous roads in Colchester as data from the Safer Essex Roads Partnership shows that accidents on this road are ever increasing and this proposal will only make it worse. There have been serious incidents from vehicular traffic, with cyclists, pedestrians and children all being hurt on the road. There is no clarity on how this will be managed not only when the development is fully occupied, but also during the number of years for construction traffic that will impact the local residents, traffic and our safety. These plans do not go far enough to improve safety and it is a real worry to people living in the area. Particularly, where there is not even public transport options in the area to reduce the number volume of traffic and no safe walkways and cycleways to encourage other modes of transport in the area to reduce heavy traffic and impact on the environment.

Not only is there an affect on the local roads safety, but also to the natural surroundings as currently there is a nice balance in the area of open green space for residents to enjoy, where lots of wildlife can be seen in this farmers land, such as foxes, badgers, skylarks, owls, buzzards and deer. This is an important and one of the only open green space in the area that contributes to the residents well being with access to outside space and enjoying nature. This will be impossible to deliver with the proposal of 875 dwellings impacting the habitat of wildlife.

I am already a resident of the estate just off Berechurch Hall Road and the effect this is already having on me and the local community due to stress and worry of this policy PP10 is something I hope will be considered by the council. It is already proving difficult to register at doctors, dentist, schools and amenities required living here and this policy has not considered this effect on current residents, let alone any future residents.

I urge this policy to be removed entirely from consideration to avoid unnecessary and unacceptable harm on the community and wildlife.

The respondents R.F. West Ltd, who are the owners of all of the land allocated under Policy PP10 : Land south of Berechurch Hall Road, Colchester, fully support the allocation of the land for residential development. However, evidence gathered by the respondents suggests that the proposed allocation of 875 dwellings cannot be delivered on this site. The respondents are of the view that a maximum of 600 dwellings could be achieved on this site, and the Council is advised that the allocation in Policy PP10 is reduced to up to 600 dwellings.

The land in question is considered to be unable to support 875 dwellings, principally due to the constraints on the local highway network and the need to make provision for open space, landscape buffers and sustainable drainage attenuation. The respondent’s Transport Consultants advise that preliminary junction capacity assessments undertaken have indicated that the number of dwellings that it is likely to be possible to provide at the site would be in the order of 500-600. Following pre-application engagement, including the submission of a Transport Note, Essex Highways has confirmed by email that they considered that the site may be able to accommodate up to 500 dwellings and that further transport analysis of the proposal could be undertaken at the time of a planning application. Further transport assessment is ongoing to see if some additional capacity can be achieved to realise the Council’s proposed allocation of 875 dwellings, however it is likely that the maximum number of dwellings possible would be circa 600.

Therefore, it is highly likely that there will be a surplus of a minimum of 275 dwellings that will not be deliverable in relation to Policy PP10 Land South of Berechurch Hall Road, which will need to be allocated somewhere else. The respondents can accommodate these dwellings on their land south of the A12 Marks Tey, where the allocation under Policy PP17 is presently for 1500, however, the respondents land at Marks Tey, can accommodate up to 2000 dwellings, now that the A12 widening is not going ahead. The respondents see this as a practical and deliverable solution, which would seamlessly soak up the undeliverable surplus of dwellings at Land south of Berechurch Hall Road, and from any other surpluses from proposed allocations, where the capacity of the site might be exceeded.




Progress on Meeting the Policy Requirements

Assuming that the Council accept that 600 dwelling is the maximum achievable on this site, the respondents are confident that 600 dwellings along with a neighbourhood centre, public open space and all the environmental and ecological requirements of Policy PP10 can be delivered. Ecology assessments are underway and will continue to be carried out in the Spring, winter bird surveys are commissioned to be undertaken this winter.

Work is ongoing in relation to highway access to the site and active travel links; the respondent’s transport consultants continue to engage with the Essex Highways to scope out and agree the assessment work required to demonstrate that the allocation is deliverable from a highway perspective. This engagement with Essex Highways has taken the form of a Pre Application submission, in response to which Essex Highways has confirmed that the site might be able to accommodate up to 500 dwellings subject to further highway capacity analysis, the results of which both ECC and CCC think is acceptable and agreeing substantial public transport, cycling, walking, travel planning and junction capacity improvements (works and/or contributions). A summary of the current highway and transportation position is set out on page 21 of the Promotion Document submitted with these representations. Presently, there are no impacts identified that would suggest that the development of up to 600 dwellings could not be deliverable from a transport and highway perspective.


Development Viability

The respondents took part in the consultation for the preparation of the Colchester Whole Plan Viability Assessment (October 2025) prepared on the Council’s behalf by Newmark, which forms part of the Local Plan evidence base. Concerns were raised in that consultation in relation to some of the costs, values and inputs that were proposed to be used in the viability assessment. However, that consultation was solely in relation to costs, values and other related inputs, there was no indication of the proposed level of contributions that were likely to be expected from allocated sites. Since the consultation and at the behest of the Local Plan Committee, the final version of the viability assessment was published, just prior to the committee meeting that resolved to allow consultation of the Regulation 18 Local Plan. The final version of the Newmark Viability Assessment suggests a financial contribution of £25,000 per dwelling for s106 items and £35,000 per dwelling for infrastructure projects would be viable for all ‘Strategic Allocations.”

Land south of Berechurch Hall Road is identified as a strategic site and as such, a combined financial contribution of £60,000 per dwelling would be required to be bound into a planning obligation at the planning application stage, having regard to Policies H1, H2 and ST7. In the preparation of these representations, the respondents commissioned Chartered Surveyors Morely Riches to undertake a Viability Assessment of the draft allocation for 1500 Dwellings at Marks Tey, using only Newmark’s values and inputs and making provision for a combined s106 contribution of £60,000 and 30% affordable housing. The result of that exercise resulted in the development making a resounding loss. Given that the Newmark inputs were the only variables used in this exercise, it was alarming to discover that the scheme would be wholly unviable. It was even more disturbing to hear at the Local Plan Committee, the Council’s Strategic Growth and Infrastructure Manager advise Members that Newmark had told her that the Colchester Viability Assessment, was one of the most viable Local Plans they had ever reviewed. The respondents have not had access to Newmark’s viability model, so it might be that if access was granted, then it could be shown that the development would prove to be viable. However, the model used by Morley Riches, is the industry standard, so the massive discrepancy is unlikely to be as a result of applying a different modelling method. The Morely Riches Viability Assessment is submitted with these representations.

Prior to making these representations, a virtual meeting was held with the Council's Strategic Growth and Infrastructure Manager to alert her to the respondents' grave concerns with regard to the Newmark viability assessment. Rather than objecting to the plan, the respondents were advised by the Strategic Growth and Infrastructure Manager to raise their concerns in these representations, which we have done. The respondent was further advised that once the consultation deadline had passed, she would instigate a review of the viability assessment and a meeting with Newmark and relevant stakeholders to assess the viability assessment and to perhaps allow access to the Newmark model. Land owners and promoters need to be confident that the final and adopted Colchester Whole Plan Viability Assessment will demonstrate that the level of contributions expected from strategic and other development would be at a level that allows development to proceed. The respondents reserve the right to make further representations to the Council and to the examining Inspector in relation to the viability assessment, in the event that the concerns raised now are not allayed.

The respondents would also like to raise their grave concerns as to the infrastructure costs that have informed the level of contribution required within the viability assessment of £35,000 per dwelling.

It would appear that amongst other infrastructure requirements that two key elements of proposed infrastructure are, The RTS 2, Colchester City Centre to Marks Tey, which has been costed at £37 million and the Park and Choose site at Marks Tey, which is understood to have been costed at £67 million. The cost of these and other infrastructure development have been contributors to setting the level of £35,000 per dwelling, that makes up the majority of the £60,000 per unit contribution. However, there are no schemes or publicly available plans of these proposals available, they are at this stage simply ideas, and whilst it might be possible to estimate a cost for their delivery, it cannot be the case that estimated costs for infrastructure that is yet to be shown to be deliverable, can reasonably be used to set what will be a lasting land compelling level of financial contribution embedded within the evidence base. If nothing else, the cost of this infrastructure must be known in detail, and informed by actual and deliverable proposals, before they can be used to set expected infrastructure payments from development under policy ST7.

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

See full text of the attachment for each policy which in some cases add extra information that couldn't be included fully in the rep summary.

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

see attached

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.

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.

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