See Full Submission attachment

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