PP17 to be read with PP18. These forced enlargements of the village of Marks Tey are trebling the size of the settlement. It is acknowledged that the village is already split by the highways and railway.

There is no attempt by the planners to bring cohesion and connectivity, especially for pedestrians. It is unlikely that developers will have these aims in mind even when applying the conditions for use of space. Consideration must be given to binding the north and south areas of development by oversailing or diverting the highways before any development is progressed.

The context and assumptions behind the Marks Tey Growth Area have been completely altered by the decision to abandon the A12 improvements. In the absence of any long term solution for the A120, which also takes account of any further development to the east in Braintree District the delivery of development within the Plan period to 2041 must be questionable. However, the location of Marks Tey, with a rail station and access to the strategic highway network means the long term potential for growth at Marks Tey has to be recognised. The vague references in the supporting text paras.12.16 - 12.19 to 'an opportunity for Garden Village scale growth' do need significant re-defining and strengthening to provide both clarity and a long term vision, with an indication of appropriate and realistic scale for the Plan period to 2041 and beyond. This needs to be informed by a comprehensive set of broad master plan principles that would replace Policies PP17 and 18. The Master Plan should demonstrate if, or how, development north of A120 and south of the A12 can form a coherent community with successful placemaking and how any development deals with the A120 and access to the Rail Station. Whilst the overall scale would need to be substantially less than the previous proposed 'Garden Community' the Council has an extensive library of background information and evidence to draw on. The boundaries of the current allocations in PP17 and PP18 are arbitrary, based on land ownership rather than any place making principles or vision and should be withdrawn. PEP5 is probably undeliverable as currently shown following the A12 decision. The residents of not just Marks Tey but of all the villages on the west side of Colchester deserve a better Plan than this. Aldham Parish is aware of, and supports, work that has been undertaken on behalf of Marks Tey Parish Council on some options for how proposed development at Marks Tey could be shaped. We encourage the City Council to work with local communities to ensure the Reg.19 Draft proposals for Marks Tey can be supported.

The Parish Council are very concerned about the total number of homes
proposed-300 for PP29 and 1500 for PP17-6, 600 of which will be within the Copford with Easthorpe Parish Boundary-we are concerned about 132% increase in dwellings and exactly how and where the homes and necessary infrastructure can be delivered.

We do not believe this meet Section 2.19 of the Vision for the Local Plan, nor Objectives and Policies of our Neighbourhood Plan.

Infrastructure delivery, (water, wastewater, roads networks/Transport, health/well-being, environment, community and education) are not clearly addressed.

The provision of public open space to accommodate formal and informal sport and leisure as required by requirement b) of the policy is supported as a development of 1,500 dwellings would justify on-site provision for sports facilities. The additional demand associated with the scale of development will be difficult to be met by improving the capacity of nearby facilities in the local area. The policy could be improved by requiring the provision of an open space, sport and recreation strategy to be prepared to support development proposals which aligns with an approved masterplan in order to provide a strategic framework for considering open space, sport and recreation provision in future planning applications. Such a strategy could also consider the needs of potential longer term growth outside of the Local Plan period. This approach would be justified by the Council’s sports evidence base, Policy CS4: Sports Provision and Government policy in the NPPF especially paragraph 103.

Dear sir, I would like to object to the proposal for more homes near the A12, there are many new developments being built between colchester and Chelmsford which will all use the road. It often cannot cope now, with the planned houses already approve increases traffic further it won’t be able to cope. Please don’t add more traffic until the A12 improves have been implemented. Thanks [NAME REDACTED]

Two thirds of this site is actually in Copford, with approximately 600 of the 1500 homes proposed falling within Copford.

As a resident of Feering I object to development of this scale without the pre requisite of completion of A12 and A120 improvements, and other community based capacity available for education, medical practices and local shops. The combined impact of the proposed development in tiptree and selves on Feering ( e.g current plan for 5000 new dwelling in Kelvedon kings dene)

Active travel includes horse riding

We agree that Marks Tey will grow but we feel strongly that the proposed plan is not the way to do it.
Marks Tey needs a detailed overall development plan to predict the extent of its growth and how that will be achieved.
This plan will need to propose infrastructure planning and growth prior to choosing sites for new housing.
Traffic planning must form a key role in this planning as our roads are under huge pressure already by the A12 and A120.
The proposed sites and plan will not work for Marks Tey and its surrounding villages.

We agree that Marks Tey will grow but we feel strongly that the proposed plan is not the way to do it.
Marks Tey needs a detailed overall development plan to predict the extent of its growth and how that will be achieved.
This plan will need to propose infrastructure planning and growth prior to choosing sites for new housing.
Traffic planning must form a key role in this planning as our roads are under huge pressure already by the A12 and A120.
The proposed sites and plan will not work for Marks Tey and its surrounding villages.

The Colchester site allocation policies and the infrastructure policy should make it possible to secure adequate infrastructure to support the proposed growth. However, it will be important for this mitigation to consider planned development in Colchester and Braintree districts in a coordinated way.

I want to ensure that our green spaces, PRoW are protected despite all of this development. Access to the countryside is already limited but research shows how beneficial it is to us all. Safe access for all users, walking, cycling and horse riders, the latter is often forgotten, needs to be included in planning and considered.

Under this Policy there is a proposal to build 1500 homes on land South of the A12 which is described as ‘Marks Tey’. However a closer examination of this parcel of land reveals that it straddles both Marks Tey and Copford parishes. A rough examination of the size of the allocated site and the number of homes allocated to it leads to an estimate of approx. 600 of the 1500 homes being built within Copford Parish. This means Copford’s total allocation of homes would be in the region of 900.

However, given CCC’s recent refusal of a planning application in Tiptree because the proposed development straddles adjacent boundaries it would be reasonable to assume that CCC will follow its own precedent on this point and withdraw PP17 from the Plan. It would also help ease Junction 25 congestion.

I accept that there is a need for housing in the Colchester area and why Marks Tey is seen as a growth area. However, I believe that there should be a lot more planning with a masterplan that covers the entire area and includes infrastructure so that a comprehensive plan is being made for future growth.
This comment applies to PP18 as well.

The Preferred Options rely greatly on Marks Tey to provide a disproportionate amount of the extra facilities required by the City yet it gives no detail on how that will be provided, to what standards, supported by what infrastructure, and in what phases. This gives no proof that this can be delivered and thus puts the whole Local Plan at risk (like 5 years ago). This could be approached by withdrawing the specific allocated sites and committing to a wholistic development plan for the area with aspired standards to be shared, discussed and agreed with the local community. Also development in Marks Tey split across the A12 without solving the division and separation of the A12 simply will further split the parish and commits the same mistakes made 50 odd years ago with the Marks Tey estate plus leading to likely cojoining with Copford. Is this what is intended - if so tell the community.

The only advantage to this site is that it has a willing owner and developer and it is likely to impose least additional traffic load on the A120. It however, uses 60% of Copford land and will inevitably lead to cojoining with Copford and thus the further spread of urban Colchester to its boundary. There are no proposals for overcoming the separation of the A12 to the rail station nor the rest of the village and it is difficult to see that there could be any effective mitigation. The call for Masterplanning is for the site only with no expectations of how it should relate to other developments or the existing community. It will commit the same problem as was committed in planning terms with the original Marks Tey estate in 1960-70s - planning in isolation.

I agree with the objectives. I have concerns that building plans for houses in Marks Tey will not meet some of those objectives, namely sustainable and well connected.

- we have ongoing issues with rats on the estate due to the ongoing issues with water pipes which need repair due to the poor construction when first built. This work disturbs the rats and they come into garages and gardens. The impact on wildlife and residents should be carefully risk assessed
- I am concerned that the drainage systems for sewage and surface water will not cope with 1500 homes which will cause flooding and health risks from waste water
- to be well-connected, Marks Tey needs a GP surgery and dentist - which it doesnt have
- Marks Tey rail station car parks are full to capacity every day. Cycling and walking to the station are dangerous options due to narrow path and heavy traffic
- the A120 is very busy and traffic is often slow making it difficult to leave the estate and area to get to A12. There needs to be viable exits from any new estate onto A12 and other key road to avoid detrimental impact to A120

The respondents R.F. West Ltd, who are the owners of all of the land allocated under Policy PP17 : Land South of A12 Marks Tey, Growth Area, fully support the allocation for 1,500 dwellings and associated infrastructure on the land.

Policy PP17 was prepared at a time when the widening proposals for the A12 Chelmsford to A120 Trunk Road were likely to proceed, having been the subject of a Development Consent Order (DCO). However, following the conclusion of a Spending Review, the Government has taken the decision to cancel the A12 Chelmsford to A120 scheme. The respondent’s masterplan proposals that were put forward during the Council's Call for Sites exercise, were prepared in the expectation that the widening scheme would go ahead, so the submitted masterplan concept was designed around the route of the widening proposals through the respondent’s land. As that scheme has now been abandoned, the land sterilised by the road widening scheme in the respondent’s ownership is now available, and the opportunity exists to increase the number of dwellings in the Marks Tey Growth Area to up to 2000. Attached to these representations is the respondent’s Promotion Document that includes a concept masterplan that illustrates a possible development without the A12 widening, which accommodates up to 1500 dwellings, along with a Neighbourhood Centre, Primary School site, Commercial Development (employment site) and associated infrastructure. However, in addition a second concept masterplan is included within the Promotion Document that accommodates up to 2000 homes, with the same supporting development and infrastructure.

The respondents also own the land the subject of Policy PP10: Land South of Berechurch Hall Road, Colchester, which allocates the land for 875 dwellings. The land in question is 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 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. Therefore, the Council is invited to expand the allocation on the Proposal Map for the Submission Draft Local Plan Regulation 19, as the site boundaries as shown on Drawing no : CN096 01-LP-001 submitted with these representations.

Progress on Meeting the Policy Requirements

PP17 sets out criteria that need to be met to demonstrate that the allocation is deliverable. The land allocation as shown on the draft Proposals Map can comfortably accommodate the 1500 dwellings proposed, along with the required open space, commercial uses, primary school and associated infrastructure. However, the land ownership could also accommodate a further 500 dwellings alongside the supporting development required.

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 and National Highways to scope out and agree the assessment work required to demonstrate that the allocation is deliverable form a highway perspective. This work and discussions with the highway authorities is ongoing and a summary of the current position is set out on page 34 of the Promotion Document submitted with these representations. Presently, there are no impacts identified that would suggest that the development would not be deliverable from a transport and highway perspective.

Ecology assessments are underway and will continue to be carried out in the Spring, winter bird surveys are commissioned to be undertaken this winter.



Consultation with Stakeholders

An informal meeting has taken place with the planning representatives of Marks Tey Parish Council (MTPC) who will no doubt make their own representations. However, the initial impressions received at the meeting were that MTPC accept that the Parish was due an allocation/s, owing to the presence of the railway station and the fact that there had not been any significant growth in the Parish for more than 40 years. Similar discussions are planned for engagement with Copford Parish Council, as a significant part of the proposed allocation falls within Copford. More formal Public Consultation will be undertaken following the adoption of the Local Plan and prior to any formal work being prepared to develop a masterplan for submission and agreement with the Council.

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 Marks Tey 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.
The Colchester Infrastructure Audit and Delivery Plan and the Colchester Local Plan Review: Further Transport Evidence which form part of the Local Plan evidence base include the proposal of a second Rapid Transport System RTS 2 between the City Centre and Marks Tey to manage the transport impacts arising from the proposed Marks Tey growth area. The respondents question the need and deliverability of the RTS 2. Presently, there are no plans or identified routes in place and the respondents are of the view that RTS2 would not be workable were it to involve Lexden Road, due to the width of carriageways and the impacts on heritage assets. The respondents consider that that there are lower cost and deliverable alternative approaches of looking to achieve a modal shift away from the private car for journeys between Marks Tey and the City Centre that should be considered, namely: -

• Promoting the use of the existing mainline train services that run between Marks Tey and Colchester North station. The infrastructure is already in place,
and the services operate with total segregation from road traffic. It is considered that means that the services provide the potential for reliable journeys between Marks Tey area and the City Centre without the significant cost and disruption of implementing the RTS. Planning development to take advantage of existing rail services is a key aspect of the consultation draft National
Planning Policy Framework; or

• Routing buses along the A12 from Marks Tey to the Northern Approaches Park & Ride (near the Stadium) and then using the existing RTS from there to Colchester. In the light of the above, ITL have undertaken investigations in relation to local bus timetables and journey times in the context of journeys between Marks Tey and Colchester City Centre. The information was considered in the context of 3 scenarios, namely: -

• Scenario 1 – Provide buses from Marks Tey to the A12 junction 28 park and ride site, via the A12, and then use the existing park and ride services to access the City Centre;

• Scenario 2 – Existing direct services from Marks Tey to the City Centre; and

• Scenario 3 – Provide a direct bus service, with priority measures,
between Marks Tey and the City Centre.

Further details on alternative transport options are explored on pages 37-40 of the respondents PP17 Promotion Document submitted with these representations.

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

Very surprised to see a reference to "TCBGC" in point 12.4 and "opportunity for garden village scale growth" in 12.17. This is a proposal that has twice been found to be unviable by the Planning Inspectorate. The concept of this being a "strategic location" is completely undermined by the scale of the recognised "infrastructure improvements" and no plan to widen the A12.
LP priorities are brownfield over greenfield, small developments and low/zero carbon. Come on Colchester - let's forget this car-dependent, archaic behemoth and look at sites where we can achieve the great LP ambitions!

The two mini roundabouts are a nightmare off the A120. Access to popular nurseries are a nightmare in and out. Anymore accesses and exists to the A120 cannot be tolerated ie: more crashes . The A120 must be improved. Also give way signs at the mini roundabouts should be reinstated they were removed as they slowed down traffic.
Proper pavements along the A120 from popular nurseries to A12 exit . Also a Zebra crossing is required at all bus stops on the A120

The A120 is constantly very busy emergency services have trouble getting through all the time . eg: Lorries + Deliveries.
Services as Doctor Surgeries are already full. Walking along the A120 to the Station and Shops is risky as paths are narrow and certainly cannot cycle on the A120. If there are going to be a large number of housing to be built causing roads to breakdown and need resurfacing. And then at least 2 car per new house wanting to get onto the A120 probably have a queue as this is the situation now. Schooling is another consideration drop offs always block the road on the estate and running their car with fumes coming out not good for children and adults. As mentioned problems with Doctors surgeries its hard enough now. There are not the facilities available to have more houses &homes. We always have to wait for ages to get onto the A120 its our only option to get home as all on the estate, due to how busy the road is.
Changes required:
Don't build large numbers of houses off the A120 -Road is not big enough , paths are not good as not wide enough to get away from lorries, delivery vehicles and fumes

The proposal of two new residential areas in the Marks Tey area is an absurd proposal!
I assume the planners have never travelled along the A120 from Marks Tey to Braintree and back - if they had, they would not be adding 2500 homes and vehicles to the area.
The A120 (MT -B) already has 23000 vehicle users a day, which could rise to 26000 with the addition of the proposed new homes. The road has not been fit for purpose in the 33 years I have lived in the village, a much needed by-pass has been long awaited.

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.

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

SEE ATTACHED

see attached

1.29 The Marks Tey Neighbourhood Plan adopted in May 2022 after a Parish Referendum which was accepted by an overwhelming majority and legally accepted into the Local Plan, is completely overridden by the Preferred Options Local Plan 2025.

National Highways welcomes the opportunity to provide comments on the 'draft Local Plan 2041 or the 'Preferred Options' for Colchester.

National Highways has been appointed by the Secretary of State for Transport as a Strategic Highway Company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network(SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting as a delivery part to national economic growth.

Within this area the SRN comprises of the A12 and A120 between the A12 and the port of Harwich.

In responding to local plan consultation, we have regard to Dft Circular 01/2022 The Strategic Road Network and the delivery of sustainable development (the Circular) which sets out how interactions with the Strategic Road Network should be considered in the making of local plans.

In addition to the Dft Circular 01/2022 the response set out below is in accordance with the National Planning Policy Framework (NPPF) and other relevant policies.

Based upon our initial review of the reports and other supporting documents available to us we have identified the items below, where we require further information and or clarification to help in completing our review of the draft plan.

The plan commits to the delivery of approximately 20,800 homes and 41.7Ha of employment land over the plan period.

At present, based upon our review, National Highways is unable to determine whether the level of growth proposed can be accommodated on the SRN, as the transport evidence base and the Strategic Transport Assessment which support the plan are still being developed. While we have been involved in a number of meeting and discussions to date,, these have not yet reached a conclusion

It is anticipated that a final transport evidence base will be submitted in support of the plan. The provision of a robust transport evidence base will allow National Highways to work alongside the Local Highway Authorities using a clear and defined Reference Case. This will support the planning of mitigation measures to address the impacts of future developments, enable infrastructure delivery to support growth and identify appropriate mitigation alongside a strategy for funding.

Notwithstanding the above, work undertaken to date indicates that a number of locations on the SRN are already under stress, with particular concern at A12 junctions 25,26,28 and 29. In addition, sections of the main line are forecast to operate close to capacity during the plan period. A strategy to address these issues is currently being developed. National Highways also has concerns that the trip rates applied within the model may be optimistic and therefore could underestimate the impact of the Local Plan on the highway network. We note that not all forecast growth arises from the proposed Local Plan and that network conditions would remain challenging even in the absence of the Plans growth.

The work to date has assessed two scenarios, including one incorporating the A12 J19-J25 DCO improvement scheme, the funding for which was formally withdrawn in the summer of 2025. This change has necessitated a review of the Local Plan and its supporting evidence.

We welcome and fully support the Plans commitment to the delivery of an integrated and sustainable transport network, including measures to encourage modal shift to public transport and active travel. We recognise, however, that achieving a meaningful reduction in car dependence will be challenging. We welcome the commitment to Bus Rapid Transit, and emphasise that if development within the Plan is to come forward in a sustainable manner, the timing and coordinated delivery of development supporting infrastructure will be critical, noting that this remains a significant challenge for plan led growth.

Environmental transformation and climate change

It is noted that the submitted draft Local Plan and the identified site allocations will increase the number of residents living in close proximity to the SRN. As a result, it is likely that these locations will experience increased exposure to noise pollution from the SRN. National Highways will not support the provision of noise barriers located on its land as part of mitigation proposals.

The close proximity of development to the SRN also raises the potential for exceedances of air quality standards for which extraordinary measures such as a

permanent speed restriction may need to be considered. While it is acknowledged that air quality is expected to improve over time with the increasing uptake of fully

electric vehicles, this cannot be relied upon as the sole mitigation measure during the plan period.

Although several polices within the local plan require development to reduce Impacts on or improve local air quality, these provisions do not clearly address impacts arising specifically from the SRN, nor do they set out how any required mitigation would be identified and delivered. We will continue to work proactively with yourselves on these matters, however, we would recommend the inclusion of a specific policy mechanism that clearly identified:

how air quality and noise impacts associated with the SRN will be assessed and monitored: and
The range of potential interventions that may be required should adverse impacts be identified.

In addition, National Highways will not accept third party connections into its drainage systems. Development proposals must ensure that no additional surface water run off is discharged to the SRN drainage network Where necessary, drainage capacity will need to be fully assessed and upgraded by the developer to ensure no adverse impact on the SRN.

Health and Wellbeing

We support the policies which set out requirements for new developments to deliver inclusive, active and environmentally sustainable modes of travel, including measures to promote road safety and to manage the negative effects of road traffic on sustainable modes. We look forward to continuing to work collaboratively with you to facilitate such travel particularly where there is an an interface with the SRN .

Lorry Parking

Lorry parking is a national problem, with particular pressures evident in East of England. National Highways would therefore welcome the investigation and allocation of a dedicated lorry parking facility within the Local Plan, ideally located in close proximity to the SRN. Where this is not achievable we would support the inclusion of a policy requirement for adequate lorry parking and overnight layover facilities to be provided as part of proposed employment sites and roadside service facilities. For context, we enclose a copy of AECOM report dated June 2019 (Appendix 2) which sets out the background evidence underpinning this request

Eight Ash Green and Copford,

National Highways is willing to work with the council and developers to explore opportunities to bring these sites forward. However, A12 J26 is currently operating very close to capacity and options for physical highway improvements at this location are extremely limited. The acceptability of development at this junction will therefore depend on whether queues on the slip road can be effectively managed to prevent interference with the A12. If this risk cannot be adequately mitigated, National Highways reserve the right to object to development at these sites, on the basis that it could give rise to a severe highway safety concern.

Marks Tey

The Plan identified three large site allocations. While the level of development proposed within the plan period does not represent the full quantum of development promoted for these sites, the principal of significantly larger scale development is established through allocation. Capacity on both the A12 and A120 is extremely constrained, and these corridors are not capable of accommodating additional growth without significant intervention. While it is acknowledged that Local Plan growth is only one contributory factor to existing and forecast congestion, there are currently no proposals for capacity enhancements on either route

Furthermore, development in close proximity to these corridors constrains opportunities for future improvements, particularly in the vicinity of A12 Junction 25, where land availability and operational flexibility is limited.

National Highways remains committed to continue to work with your authority in a collaborative and constructive manor to support the progression of the plan. We will continue to work with you to develop a clearer understanding of the impacts of proposed development upon the SRN and to explore whether, and how, such impacts could be accommodated.

We trust the above comments are helpful in informing the progression of your proposals and welcome continued engagement and discussion with the council on these matters.