as previous

My comments in my repesentations in PP17, PP18 and PEP5 are relevant for PEP6 and should be included in my submission for PEP6

The Andersons site has seen expansion of a lorry park bringing light pollution and increased lorries and vans to the A120 and Old London road. no roundabout was added as proposed. It is difficult to pull out of London road onto the A120 on leaving the village hall and recreation ground. Extra employment premises will not help congestion and what would this employment be?

This area has already developed adding lorries and vans to the local roads. There is light pollution in what was a dark sky area. The access road to Andersons is on old London road, a small residential road that joins the A120 at the pinch point of the Marks Tey interchange roundabout causing delay and difficulty in exiting Old London road.

Potential to impact BR 28. PRoW should be easily accessible and expanded to ensure continued access to green space for new and existing residents.

Close proximity to Bridleway 10 Marks Tey and Bridleway 28 Copford. Care should be taken to maximise accessibility links to both PRoWs within any new development. Equestrian interests and infrastructure in both Copford, Marks Tey and Greay Tey. A more inclusive, linked network should be focused on within the development. Bridleways are not just for horses and do not require any additional infrastructure beyond that of a cycleway. They do not cost more money. A lack of knowledge about equestrian user groups is not a sufficient basis for discrimination.

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

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.