as previous

The reference to a “community space” provides an excellent opportunity to deliver a multi‑functional community arena that could support a wide range of activities, including equestrian events, dog‑related activities, local fairs and seasonal markets. Incorporating such a space would create a genuine community hub while also strengthening the green infrastructure of the site. By linking this community arena to Footpath 21, the development could establish a circular multi‑user route around the proposed development, supporting safe, inclusive access for walkers, cyclists and equestrians and enhancing connectivity across the wider network.

Area shown to NW of Wivenhoe outside the village development limits:
Wivenhoe is one of only two towns within Colchester City boundary, the other being West Mersea. Unfortunately we do not have the advantage of West Mersea being cut off from Colchester twice a day due to high tides.

Wivenhoe is separated from Colchester City by the University of Essex on the north west and the River Colne to the south west. The area of farmland between the B1028 Colchester Road and the University’s Boundary Road and the stream that runs through its centre is an important green space separating the distinct development areas and giving open views from Broomfield School and the wider Broome Grove estate.

Wivenhoe is at the extreme edge of Colchester City area bounding Tendring to the north and east on which boundaries we are soon to be joined by the Tendring Colchester Borders Garden Community, a development that will add to the existing pressures on transport and public services.

Road transport from the Town travelling west is at or over capacity, sometimes taking an hour to reach the A12. The A133 route of Clingoe Hill, Cowdray Avenue and Remembrance Avenue is already a disgrace to Colchester. Bus times are slightly better as they still have the advantage of using Boundary Road though the University.

Public services and facilities are mostly at capacity or over-subscribed and will be further stretched once the Garden Community is built, initially with no facilities.

The housing priority for Wivenhoe is not another characterless estate of detached family homes or oversized bungalows in large gardens on the extremities of the town, but small terraced houses for the younger generation, as we have in Station Road, Alma Street and Queens Road or alms house style housing for the elderly, within walking distance of the station and other facilities.

I have read Colchester Local Plan and do not agree that more housing is viable in this area, particularly with the volume of properties already proposed in Tendring Garden Community and no indication of the completion of the A1331 link road. As everyone knows the roads are already congested, the hospital unable to cope, GP appointments difficult to obtain in some places etc.etc. The same old proposals put forward and reiterating the Marks Tey Community, plans which were dropped several years ago after much protest, will only cause more uproar.

I am broadly supportive of Policy PP24, provided delivery is genuinely infrastructure led and sensitive to Wivenhoe’s character. The emphasis on design quality, green infrastructure, heritage protection and active travel links is welcome. Support is particularly dependent on clear confirmation of wastewater and drainage capacity, highway safety and phased delivery to avoid pressure on existing services. It is also important that development respects the role of the Wivenhoe Neighbourhood Plan and includes meaningful engagement with local residents. With robust safeguards, enforceable infrastructure commitments and high quality placemaking, this allocation could represent sustainable and appropriate growth for the area.

I support the policy but do not support the Wivenhoe allocation which contravenes this policy. The PP24 allocation in Wivenhoe is situated within our Green Buffer. This ‘Green Buffer’ was set out as a principle in the previous Section 1 plan related to the Garden Community. Wivenhoe was guaranteed a ‘Green buffer’ as a coalescence break. This must be maintained and therefore this allocation breaks existing and proposed policy.

I object to the Wivenhoe allocation PP24.

This allocation is within the “Green Buffer” and coalescence break between Wivenhoe and Colchester. To maintain the unique character and setting of the settlement of Wivenhoe, this coalescence break must be protected. This break was set out as a principle in Section 1 of the Local Plan when passed, including the Garden Community allocation.

This allocation breaks existing and proposed policies. It would not provide an open buffer/green buffer as promised in a number of policies, and it fails to meet existing protections outlined in the current plan.

Colchester Local Plan
Regulation 18
Land Northwest of the Fire Station,
Wivenhoe
On behalf of
Manor Oak Homes and Mr Charles Gooch
January 2026
CONSULTATION
RESPONSE
TABLE OF CONTENTS
1. INTRODUCTION..........................................................................................................................................................1
2. THE SITE.......................................................................................................................................................................5
3. POLICY PP24...............................................................................................................................................................7
4. POLICY GN5, SUSTAINABILITY APPRAISAL AND EVIDENCE BASE.................................................................19
5. CONCLUSION ...........................................................................................................................................................24
Appendix A - Revised Site Plan (Red Line) – SLP-01 P4............................................................................................26
Appendix B – Recommended Amendments to Policy PP24...................................................................................27
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1. INTRODUCTION
Background
1.1 This representation is prepared on behalf of Manor Oak Homes and Mr Charles Gooch (the
Promoters) in respect of the Colchester City Council Preferred Options Local Plan Regulation 18
Consultation.
1.2 In January 2024 Ceres Property were instructed to make ‘Call for Sites’ submissions in respect of
three land parcels on the northern side of Wivenhoe (Site IDs: 10755, 10757 & 10756). The
submissions were accompanied by a Constraints and Opportunities Plan which was submitted in
support of potential development sites, and is reproduced at Figure 1 below.
Figure 1: Constraints and Opportunities Plan
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1.3 For Wivenhoe, Policy PP24 proposes to allocate Land Northwest of the Fire Station, Colchester Road,
Wivenhoe for approximately 175 homes. This is predominantly the southern land parcel shown on
Figure 1 above, and subject to some revisions and commentary as set out below, is the focus of this
representation.
1.4 This representation provides formal comments on the draft policies within the plan considered
relevant to our client’s interests, in particular Policy PP24.
1.5 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
principle of the inclusion of Policy PP24 in the Plan. They welcome the opportunity to work with
Planning Officers to further refine the Policy and ensure that the site is both a developable and
deliverable housing opportunity.
1.6 While they are obviously disappointed the other two land parcels have not been proposed as
allocations, we would like to confirm that they are both still available, either in their entirety or in
part for inclusion in the emerging plan, in the event further sites are required to meet the Council’s
substantial housing needs and ensure there is a sufficient supply of sites to do this over the plan
period.
Policy Context
1.7 In preparing these representations, regard has been had to the National Planning Policy Framework,
December 2024 (NPPF). Paragraph 11 of the NPPF sets out:
Plans and decisions should apply a presumption in favour of sustainable development.
For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to: meet
the development needs of their area; align growth and infrastructure; improve the
environment; mitigate climate change (including by making effective use of land in urban
areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for
housing and other uses, as well as any needs that cannot be met within neighbouring
areas, unless:
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i. the application of policies in this Framework that protect areas or assets of particular
importance provides a strong reason for restricting the overall scale, type, or distribution
of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the
benefits, when assessed against the policies in this Framework taken as a whole.…
1.8 Section 3 of the NPPF relates to ‘plan-making’. Paragraph 15 of the NPPF promotes a plan-led
system, and that succinct and up-to-date plans should provide a positive vision for the future of
each area; a framework for addressing housing needs and other economic, social and
environmental policies; and a platform for local people to shape their surroundings.
1.9 Paragraph 16 states that Plans should:
a) be prepared with the objective of contributing to the achievement of sustainable
development;
b) be prepared positively, in a way that is aspirational but deliverable;
c) be shaped by early, proportionate and effective engagement between plan -
makers and communities, local organisations, businesses, infrastructure
providers and operators and statutory consultees;
d) contain policies that are clearly written and unambiguous, so it is evident how a
decision maker should react to development proposals;
e) be accessible through the use of digital tools to assist public involvement and
policy presentation; and
f) serve a clear purpose, avoiding unnecessary duplication of policies that apply to
a particular area (including policies in this Framework, where relevant).
1.10 As set out at paragraph 36, local plans are examined to assess whether they have been prepared in
accordance with legal and procedural requirements, to determine whether they can be considered
‘sound’. The test for soundness as set out within the NPPF requires that Plans are:
a) Positively prepared
b) Justified
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c) Effective
d) Consistent with national policy
1.11 By way of background to the Council’s preparation of the emerging Local Plan, it is acknowledged
that the Council’s current five year land supply is increasingly marginal.
1.12 In February 2026 the existing Adopted Section 1 Local Plan becomes five years old, and the housing
requirement within it will accordingly be out of date for the purposes of calculation of five year
housing land supply as set by NPPF paragraph 232. At this point in time the Council accept that they
will be unable to demonstrate a five year housing land supply and this situation is unlikely to be
rectified until the adoption of the new Local Plan.
1.13 The housing land supply annual requirement will therefore become approximately 1,300 dwellings
per annum in line with the standard method, as opposed to 920 dpa within the existing adopted
Local Plan. Over a five year period this will add 1,900 homes to the required supply, plus the required
buffer.
1.14 The Council acknowledges this requirement at paragraph 3.36 of the Regulation 18 Consultation
document, confirming that the requirement for 20,800 new homes over the plan period is a
mandatory target (or minimum target [emphasis added] ) which must be planned for. At present
the draft Plan proposes to deliver 21,106 new homes which equates to a headroom of just 1.1%.
There is also a significant Affordable Housing need in the Borough, which the 2024 Housing Needs
Assessment indicates equates to 877 affordable dpa. Both these factors suggest that it is likely that
the Regulation 19 Plan will need to establish a higher total requirement figure, not only to provide
an appropriate buffer of a minimum 5% but also to boost overall numbers to help address acute
affordable housing needs.
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2. THE SITE
2.1 On 7th February 2025 the Council published papers for the Local Plan Committee meeting to be
held on 17th February which included a full draft of the Regulation 18 Preferred Options Local Plan
and the inclusion of Policy PP24. While at that time the resolution to publish the plan for consultation
was not agreed, the draft Plan sought to allocate sufficient sites to provide for 1,300 dwellings per
year across the new Plan period to 2041. For Wivenhoe, Policy PP24 proposed to allocate Land
Northwest of the Fire Station for approximately 175 homes.
2.2 As stated above, Manor Oak Homes and Mr Charles Gooch welcomed the proposed inclusion of the
Land Northwest of the Fire Station as an allocation in the emerging Local Plan. Having reviewed draft
Policy PP24, the Promoters have been working with their consultant team to progress further
technical work to help support the Site’s early delivery. Updated plans and technical notes/reports
have now been produced to provide further evidence to support the Site’s inclusion as both a
developable and deliverable opportunity. These confirm that, a development with the following
description could be brought forward;
A proposed residential development of approximately 200 dwellings with land for a new
community space, associated public open space, landscaping , and infrastructure.
2.3 A positive meeting with officers from the Council’s Planning Policy Team was held on 16th December
2025 to provide an update on the progress which has been made to date. The following documents
were provided to the Council ahead of the meeting:
• Revised Site Plan (Red Line) – SLP-01 P4: Produced by Thrive Architects
• Wivenhoe Constraints and Opportunities Context Plan – COP-01 P4: Produced by Thrive
Architects
• Concept Master Plan Option 1 – CMP-02 P7: Produced by Thrive Architects
• Concept Master Plan Option 2 – CMP-02 P8: Produced by Thrive Architects
• Land Budget Plan Option 1 – LBP-02 P7: Produced by Thrive Architects
• Land Budget Plan Option 2 – LBP-02 P8: Produced by Thrive Architects
• Proposed Access – 1255-TA11: Produced by Martin Andrews Consulting
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• Arboricultural Impact Plan – OE-002 October 2025: Produced by Origin Environmental
• Technical Note – Highways: Produced by Martin Andrews Consulting
• Indicative Attenuation Requirement – 1255-FRA03 Rev A: Produced by Martin Andrews
Consulting
• Technical Note – Flood Risk and Drainage: Produced by Martin Andrews Consulting
• Landscape & Visual Technical Note – October 2025: Produced by Aspect Landscape Planning
• Preliminary Ecological Appraisal – September 2025: Produced by Blackstone Ecology Ltd
2.4 Apart from the Revised Site Plan (Red Line) – SLP-01 P4 (at Appendix A) these have not been reprovided as part of the consultation response; however, further copies can be made available if
required.
2.5 Following the submission of this representation it is the Promoters intention to work up a formal
pre-application submission to help further develop the detail of site proposals ahead of the potential
submission of an outline application later in the year, which will help to confirm that the Site is
developable and provide a clearer indication of when housing delivery may actually commence.
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3. POLICY PP24
Supporting Text
3.1 The supporting text for Policy PP24 is set out at paragraph 12.24 of the draft Plan. This confirms that
Wivenhoe benefits from a good range of infrastructure including a mainline train station, GP surgery,
two primary schools, numerous shops and restaurants, and abundant open space provision. It also
benefits from public transport connections to Colchester and a good cycle and footpath network
which provides good connections to the University of Essex, amongst other destinations. As such,
the Town can be acknowledged as a sustainable location, in line with the Plans development strategy
for the accommodation of further growth.
3.2 Paragraph 12.24 also acknowledges there are a number of environmental constraints which
reasonably restrict the opportunities for the town’s expansion to the south, east, and west, which
confirms the only logical direction for some proportionate growth is to the north.
3.3 There is also a made neighbourhood plan for Wivenhoe, the Wivenhoe Neighbourhood Plan
(Adopted May 2019), which has helped to guide development in the past, whilst safeguarding the
surrounding environmentally sensitive areas. Whilst this is part of the Development Plan, it is now
over five years old and as such the weight which can be attributed to its policies will need to be
moderated to reflect the increased local housing requirement.
Policy PP24: Land Northwest of the Fire Station, Wivenhoe
3.4 The requirements of Policy PP24 are set out in turn below with comments and responses provided
to each of the relevant criteria. Overall, the allocation is supported with the proposal for
approximately 175 new homes, or more to make the most efficient use of the Site, considered
appropriate, given the sustainability of the settlement, and Wivenhoe’s position in the Borough’s
settlement hierarchy. There are, however, a number criteria within the Policy which it is considered
might be better worded, require clarification, or are not actually considered to be necessary to
enable the effective delivery of the allocation.


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Policy PP24: Land Northwest of the Fire Station, Wivenhoe
In addition to the infrastructure and mitigation requirements identified in Policy ST 7 and subject to
compliance with all other relevant policies, development will be supported on land within the area
identified on the policies map which provides:
3.5 As referred to above the extent of the Site boundary (red line) has been reviewed as part of the
current scheme development; in particular having regard to the landscape, ecological and access
technical work which has been completed to date. Some revisions to the Site boundary are now
proposed and these are included on the accompanying Site Plan SLP-01 P4 which is attached at
Appendix A. The extent of the Site and development boundary shown on the draft policies map we
consider should be updated to reflect the full extent of the amended site area, which is 8.828
hectares.
3.6 The amendments can be summarised as follows:
• The northern boundary: Has been adjusted to the north along Colchester Road to deliver a
better development relationship with Feedhams Close on the west side of Colchester Road
and provide a more logical settlement boundary along the northern part of the town while
allowing the slightly enlarged site to deliver an appropriate and efficient quantum of
development, reflecting the sustainability of Wivenhoe as a location. This also helps to better
accommodate the required access visibility splay to the north and provide a stronger gateway
into the settlement. Along the northern boundary from an ecological and biodiversity point of
view, it is also important to include a 5m buffer on the north side of existing hedgerow, ditch,
and tree cover, for enhancement and management purposes, however this area will not
include any built development.
• Southern boundary: This includes the track to allotments and the former care home site.
• Eastern boundary: This follows the title plan.
• Western boundary: This follows the edge of the new of allotment site.
3.7 While these changes will marginally increase the size of the site, they help to facilitate it delivering at
least the anticipated quantum of development, without compromising the ability to retain and
improve the existing important landscape trees, hedges, and ditches, and also ensure that the
biodiversity value of these features can be maximised in the long term.
a) Approximately 175 new dwellings of a mix and type of housing to meet evidenced needs and be
compatible with surrounding development;
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3.8 Criteria a) is supported, however there does need to be some flexibility in respect of the total
number of dwellings which can be delivered. Currently two different development options are being
developed, one which reflects the pylons which cross the site as being retained, and a second which
reflects Policy criterion j) showing them undergrounded. At present these options confirm that 175
dwellings are likely to be below the minimum number of dwellings the Site can deliver and in reality,
higher numbers will be achievable in order to make the most efficient use of the land available in
this sustainable location.
3.9 Both Concept Master Plan options seek to retain existing landscape features, primarily the existing
field boundaries. A single point of access is provided to Colchester Road with a main spine road
running through the Site and providing an all modes connection to the north-west corner of the
Cala Homes development.
3.10 To provide a vehicle connection between the eastern half of the Site and the west, it will be necessary
to remove a short central section of the existing hedgerow. This will be kept to a minimum and
compensatory planting will be carried out. Additional pedestrian connectivity has also been
provided to assist the integration of the Care Home land, the Cala development, the new allotments,
and the wider Site.
3.11 Generous areas of landscaping and green space have been included, with green buffers to existing
landscape features throughout. The landscaping will help to establish an appropriate rural character
to the scheme and some separation between the internal development parcels, reflective of the
Site’s edge of settlement location.
3.12 On the western side of the Site a surface water attenuation basin is proposed which can be gravity
fed from the remainder of the development area. This will also be located close to the existing
attenuation basin which serves the Cala development, and the new allotment site to the west,
creating a large natural space, rich in habitat value and adding a tranquil area to the setting of the
new allotments.
3.13 The Promoters architects are currently refining the site option plans to ensure that an efficient use
of the site can be delivered at an appropriate density to reflect the landscape sensitivity of the site,
however, the early indications are that a higher number of dwellings is likely to be deliverable and
as such it is recommended that the figure of approximately 175 dwellings is slightly increased to
approximately 200 dwellings. When the additional design work has been completed, we will provide
the Council with an update of the most realistic site capacity, to help inform the next stage of the
emerging Plan.
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b) Safe and suitable site access to required highway design standards and point of vehicle access to
be via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority and
demonstration that the proposal would not be detrimental to highway capacity or safety;
3.14 It is noted that criteria (b) of Policy PP24 seems to suggest that the; ‘…point of vehicle access to be via
the adjoining Neighbourhood Plan allocation…’ The existing access to the Cala development is
physically constrained by the existing buildings in Watsham Place and as such it is not considered
that it would be desirable in highway terms for it to serve approximately 260 dwellings.
3.15 As part of the scheme development process, it has therefore been concluded that providing a new
point of access further north along Colchester Road would deliver substantial highway safety and
amenity benefits, reducing the potential for congestion around the junctions of Vine Drive and
Elmstead Road. Additional pedestrian and cycle connections can be provided directly to Colchester
Road, as part of this new access, as well as to the new track to the allotments, in the south-east
corner of the Site frontage as well. A vehicle link to the Cala development is also proposed which
ultimately will create a loop through both sites. This will improve the over permeability of both sites.
3.16 In respect of the location of the new Site access on Colchester Road, a central location is considered
to be the only feasible option to serve the development. This is because there is not scope to locate
the access to the south due to the separation distance required from the Elmstead Road junction
and the controlled crossing, meaning there are no suitable non constrained alternative locations. A
Highway Technical Note and accompanying plans have already been provided to the Planning Policy
Team and further copies can be made available upon request. As the scheme development is
progressed engagement with Essex County Council Highways will be undertaken to help confirm
the technical acceptability of these arrangements.
3.17 It is therefore recommended that criterion b) should be amended to the following:
Safe and suitable site access to required highway design standards and point (s) of vehicle access to be
via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority and
demonstration that the proposal would not be detrimental to highway capacity or safety .
3.18 The Promoters would be happy to discuss this or another form of suitable access with the Council.
c) Provide a safe pedestrian access to ensure connectivity within and throughout the site to existing
footways and any Public Rights of Way. Ensure provision of green infrastructure connections and
recreational access to the countryside, also securing active travel links and connections to the
settlement;
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3.19 This criterion appears to be trying to address three matters, which are generally related, however,
the reference to green infrastructure connections is considered confusing as these connections are
not only associated with accessibility but also green and blue corridors where it may be more
appropriate to discourage public activity from an ecological perspective. Furthermore, there are no
public rights of way crossing, or immediately adjoining the site. It is therefore recommended that
criteria c) is amended as follows:
c) Provide a safe pedestrian and active travel access to ensure connectivity within and throughout the
site and to the settlement and surrounding area . Connections to existing footways and the track to
the allotments and where possible recreational access to the countryside should also be considered .
to existing footways and any Public Rights of Way. Ensure provision of green infrastructure
connections and recreational access to the countryside, also securing active travel links and
connections to the settlement;
3.20 The delivery of green infrastructure connections can be secured through the statutory requirements
to deliver biodiversity net gain and the general layout of the development.
3.21 If the reference to green infrastructure connections was intended to suggest that public access
should not only be provided through the urban parts of the development, but also through more
informal rural settings, then this can be explained as part of the supporting text.
d) Contributions towards enhancement of the quality and value of King George V Playing Fields;
3.22 There is no objection to this particular criterion. While the emerging scheme which is being
developed for the Site will provide the minimum 10% open space requirement currently operated
by the Council, given the size of the development it is unlikely that this will include any formal sports
facilities, and as such it is appropriate that some mitigation should be delivered providing this is not
already captured as part of the Council’s CIL charging schedule.
e) Screening comprising locally appropriate tree belts and/or hedgerows will be required along the
site boundaries to ensure that development is sensitively integrated into the landscape and to
maintain settlement separation;
3.23 This is a reasonable requirement, and the current scheme development is being informed by an
accompanying landscape strategy which seeks to retain existing hedgerows and tree belts with
appropriate buffers and introduce new tree belts and/or hedgerows where necessary along the Site
boundaries to ensure the Site is sensitively integrated into the townscape.
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f) Biodiversity enhancement measures should include enhancing hedgerow condition and
establishing grassland habitats along road verges;
3.24 There is no particular objection to this policy criteria, however, given the statutory biodiversity
enhancement requirements which will be secured through the detailed planning application stage
and a statutory biodiversity net gain condition, it is unclear why there is a site specific requirement
for establishing grassland habitats along road verges in this particular location. As such these
comments might be better included in the supporting text of policy where further explanation and
justification can be provided.
3.25 It is therefore considered that unless there is site specific justification available this criterion should
be deleted.
g) Development must conserve, and where appropriate, enhance the significance of heritage assets
(including any contribution made by their settings). Designated heritage assets close to the
allocated site includes five Grade II Listed Buildings as informed by the stage 1 HIA;
3.26 This is in line with national policy and legislative requirements which require heritage assets to be
conserved or enhanced, not conserved and enhanced. It is considered that the Site can be
developed to ensure that the setting of the nearby listed buildings are, as a minimum, preserved.
3.27 It is noted that the Heritage Impact Assessment Sift Methodology (January 2025) classified the site
as not requiring any further investigation at this stage but indicates that a proportionate heritage
impact assessment, desk-based archaeological assessment and potentially trial trenching, should
be part of the planning application stage.
h) The total number of dwellings will be spread between this site and the area currently set aside
for a care home as part of the neighbourhood plan allocation;
This criterion is supported as it will provide clarity in respect of the status of the Neighbourhood
Plan as part of the development plan and the Site’s existing designation for use as a care home.
3.28 Following the original outline permission (Ref: 213507) in January 2024 for the adjoining housing
site, which included permission for a 60 bed care home, the site was marketed and Cala Homes
purchased the residential element, however, very little interest was expressed in the Care Home
site. More recently, in October 2024, a focused marketing exercise commenced for the care home
land. Over twenty operators were contacted directly, however, despite the extensive marketing, only
one operator expressed any serious interest, and after a more detailed review concluded the site
was not suitable for their requirements.
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3.29 It is also relevant that the care home land to the rear of the Fire Station was not the only opportunity
for care home provision to be made by the Neighbourhood Plan. At paragraph 16.35, the
Neighbourhood Plan notes this and states: “Whether proposals for care homes come forward will
depend on market factors.” Furthermore, the Council have recently resolved to grant planning
permission (Ref: 240409) at the Croquet Gardens site for 25 Bungalows and a 60-Bed Care Home.
Therefore, the care home land to the rear of the Fire Station is not required or suitable for care
home use to meet any current local need and, as such, there is sufficient justification for its logical
inclusion as part of the residential allocation.
3.30 This is also recognised in the Summary of Sites Evidence (October 2025) evidence base document
as set out in Section 4 below.
i) A new community space must be included within the site and pedestrian access to the adjacent
allotments must be created;
3.31 The Site Promoters would be agreeable to including a community space/land as part of the scheme
development, however, there needs to be a clear vision around what is actually necessary,
proportionate, and justified.
3.32 At the present time, this criterion is considered to be imprecise in respect of the size and type of
community space which is required and is lacking justification.
3.33 While pedestrian access will clearly be provided to the adjacent allotments through the inclusion of
the allotment access track, this can also be secured under criterion c) above.
3.34 Having regard to the limited information in the Infrastructure Audit and Delivery Plan (October 2025)
(IADP), which it is acknowledged does refer to a limited range of community facilities at Table 3.25
(Page 69). However, it does not expand this any further and explain which community facilities there
are a shortage of. It is noted that those facilities listed in the introduction to section seem to relate
to buildings such as community halls and libraries rather than ‘spaces’.
3.35 While the Sustainability Appraisal refers to this as a potential community benefit for residents in the
north of the settlement, it fails to provide any further guidance what is expected.
3.36 The reference in the IADP does not seem to align with the assessment set out in the Settlement
Evidence Stage 1 Document (November 2024). This evidence document includes an analysis of
Wivenhoe (Page 108 onwards) which generally confirms that it is a sustainable location with a good
range of community facilities and local services. This does not suggest a shortage of community
buildings. At Page 109 it states:
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“There is numerous community and social infrastructure in Wivenhoe. There is a GP
surgery, dentist surgeries, shops including a One Stop, Co -op and numerous
independent shops. There is a library , three hair salons and three barbers, art galleries.
There are nine public houses/restaurants, four cafes, a fish and chip shop, football
ground, tennis courts, cricket ground, bowls club, allotments and open space provision
including playing fields. Ther e are multiple churches and community halls .” [emphasis
added]
3.37 Under the section on High Level Opportunities (at a settlement level), whilst it suggests that growth
may provide opportunities to enhance local infrastructure, including active travel within the
settlement and beyond, there is no mention of a need for additional community spaces or buildings.
There is, however, reference to the Wivenhoe Green Spaces Community Project which
demonstrates how a mosaic of sites of varying sizes contribute to the green infrastructure of the
town and encourage diversity of wild flowers on green spaces, bringing significant ecological, climate,
and heritage benefits.
3.38 As referred to above, noting that the Council is a CIL charging authority and 25% of CIL receipts will
be transferred directly to Wivenhoe Parish Council to spend on local projects, there does not appear
to be any reasonable justification for this criterion at present.
3.39 Furthermore, criterion d) indicates there is a particular need for contributions towards the
enhancement of the quality and value of King George V Playing Fields which it is assumed would be
secured separately to CIL, through a Section 106 Agreement. Requiring the Site to deliver a further
additional community space or land as well as a contribution to this existing community recreation
space is not considered reasonable or proportionate to the scale of the proposed development. As
such it is not likely to be compliant with the tests set out in the CIL Regulations without further
appropriate site-specific justification.
3.40 In respect of the current scheme development work, without more precise understanding of what
a community space may be required to deliver it is difficult to understand where it might be best
located on the site, the type and extent of land required, the potential neighbouring impact it may
have and what accessibility requirements may be necessary. It would therefore be extremely helpful
to have further clarification on this matter if the criterion is to be retained.
3.41 In summary, at the present time it is therefore considered that criterion i) should be deleted or
further site specific justification should be provided.
j) Opportunities for undergrounding should be explored
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3.42 There is no objection to this criterion. At the beginning of July 2025 notice was served by the
landowner on Eastern Power Networks Plc that their Wayleave Agreement which crosses the Site,
will be terminated on 15th January 2026. This is the first step towards potentially securing the
ungrounding of the existing overhead power lines. However, at this stage it is not known whether
this is a realistically viable option. As such, as referred to above, two layout options, with and without
undergrounding, have been prepared and are being developed further.
3.43 It should also be noted that there is a mains sewer which follows the alignment of the existing Pylons
which means the two different schemes do not vary dramatically with a linear open space running
through the Site, even if the existing overhead power lines were to be undergrounded. This is not
to say there would not be visual and environmental benefits from fully exploring the opportunity for
undergrounding.
k) Development must discharge attenuated surface water to a receiving waterbody and not to the
combined sewer network, unless it can be demonstrated that there is no other option.
3.44 There is no objection to this criterion. A drainage strategy is being prepared as part of the scheme
development and, as referred to above, a technical note, Flood Risk and Drainage has already been
provided to the Council which confirms that surface water can be discharged to an appropriately
sized attenuation basin on site. A further copy of this technical note can be provided if required.
l) Demonstrate adequate capacity for managing wastewater including proposed phasing
requirements or alternative solutions to the satisfaction of the Council and Anglian Water;
3.45 As referred to above, a drainage strategy to inform the scheme development is being developed
and this will include engagement with Anglian Water.
3.46 Although as a statutory consultee, consultation would undoubtedly take place in connection with
this and other criteria, it is the local planning authority (not Anglian Water or any other body) that
makes the final decision on planning applications, accordingly it is inappropriate for Anglian to be
included in the Policy. References to the need for consultation and capacity issues if they exist can
be included in the support text.
3.47 It is relevant to note that Anglian Water have been raising issues up and down the country, objecting
to development due to insufficient capacity, and these objections are being further tested through
the courts. However, the law is clear that Anglian Water has a duty under the Water Industry Act
1991, to accept connections to the public sewer which they accept; the current issue is where there
is a shortage of headroom in the receiving waste water recycling centre (WRC), the speed at which
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appropriate capacity can be delivered. Clearly, through a plan led system, there should not be a
problem for the sewage undertaker to align its asset management upgrade programme, a five year
cycle, with the housing trajectory proposed through a Local Plan and early engagement by site
promoters as well as the local planning authority will assist with this. This is clearly a matter which
should also be addressed through the infrastructure delivery plan and in turn needs to be linked to
the Council’s housing trajectory.
3.48 In conclusion the reference to Anglian Water in criterion l) should be deleted.
m) A range of measures in addition to prioritising SuDs (Policy EN8) and water efficiency measures
to reduce the risk on impact on the WRC capacity as a result of planned growth including:
i. Removal of unrequired network flows;
ii. Targeted education to include new residents of the development;
iii. Reduction in the demand for potable water.
3.49 It is unclear why this particular criterion has been included given the requirements for a site specific
flood risk assessment and drainage strategy, which would need to be in accordance with Policy EN8
and cover the items listed as i) to iii) above. In addition, as referred to in the comments above in
respect of criterion l) consultation with Anglian Water will be required and the above issues will be
addressed through this mechanism. It will also be linked to the infrastructure delivery plan and
housing trajectory.
3.50 It is considered that it would be more appropriate for this matter to be referred to in the supporting
text rather than as an additional policy element.
3.51 Criterion m) should be deleted.
n) Any site specific infrastructure requirements from the IDP (likely to include education provision,
highway mitigation, water and wastewater and specific community / open space provision).
3.52 There is no objection to this particular criterion, however, any site specific infrastructure
requirements will need to meet the statutory requirements as set out in Regulation 122 of the CIL
Regulations 2010 (as amended) i.e. be:
(a) necessary to make the development acceptable in planning terms;
(b) directly related to the development; and
(c) fairly and reasonably related in scale and kind to the development .
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3.53 This will be particularly important bearing in mind that the Council is already a CIL charging authority
and there should be no double counting when considering infrastructure and mitigation.
3.54 In the national policy context of producing succinct local plans, as a general good practice comment
including this requirement does seem to be an unnecessary “belt and braces” approach, given the
reference to Policy ST7 in the introduction to the Policy, as well as the requirements set out in the
other criteria discussed above.
3.55 In conclusion it is recommended that criterion n) is deleted.
o) Before granting planning consent, wintering bird surveys will be undertaken at the appropriate
time of year to identify any offsite functional habitat. In the unlikely event that significant numbers
are identified, development must firstly avoid impacts. Where this is not possible, development
must be phased to deliver habitat creation and management either on or off-site to mitigate any
significant impacts. Any such habitat must be provided and fully functional before any
development takes place which would affect significant numbers of SPA birds
3.56 There is no objection to this criterion given the environmental sensitivities of the surrounding
protected sites. As part of the scheme development, ecologically assessments have been carried
out including bird surveys which were undertaken during January, February, and March 2025. These
confirmed that any use of the site by waterfowl was negligible. These results are included in the
Preliminary Ecological Appraisal which has already been provided to the Council. This assessment is
further supported by the surveys previously undertaken in relation to the CALA and Care Home site
which are also still relatively recent, albeit now out of date, but again not identifying any particular
concerns.
3.57 These conclusions are also supported by the Emerging Allocations Biodiversity Assessment as
referred to in Section 5 below.
All development Proposals within Wivenhoe Neighbourhood Plan Area, will also be determined
against the policies in the Wivenhoe Neighbourhood Plan (Adopted May 2019) where they are up
to date and relevant.
3.58 There is no objection to the final paragraph of the Policy which acknowledges the existence of the
Wivenhoe Neighbourhood Plan, which will remain part of the development plan for the area. This
helpfully confirms that the weight attached to its policies for decision making purposes in the future
will need to be moderated having regard to its age, consistency with the Local Plan strategic policies,
and national planning policy at the time of the determination of any future planning application
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PP24 Summary
3.59 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
inclusion of Policy PP24 in the Plan. While the above section includes some relatively detailed
commentary in respect of the particular criteria and wording of Policy PP24, these are not intended
to be a criticism, but a positive review to assist the Council with the drafting of the forthcoming
version of the Policy and supporting text to be included in the Regulation19 submission version of
the Plan, to help ensure that the Plan can be found sound on examination with limited modification.
3.60 A track change version of Policy PP24 has been provided at Appendix B capturing the recommended
amendments set out above. In conclusion this representation supports Policy PP24 subject to the
recommended refinements and minor amendment to the Site area as indicated at Appendix A,
ensuring flexibility, clarity, and deliverability of the Site in the early part of the Plan period.
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4. POLICY GN5, SUSTAINABILITY APPRAISAL AND EVIDENCE BASE
Policy GN5: Suitable Alternative Natural Greenspace
4.1 It is noted that the emerging Plan, includes Policy GN5: Suitable Alternative Natural Greenspace. This
policy requires that the Natural England standard of 8 hectares per 1000 head of population be
applied where it is necessary to provide alternative greenspace as the result of a Habitat Regulations
Assessment. It is proposed that the policy wording should be reviewed to allow flexibility in the
application of this ratio, as opposed to an arbitrary calculation, and consideration should be given to
only applying it strategic scale development for example, over 1,000 dwellings.
4.2 On the basis that we would anticipate that an HRA for this particular site (Policy PP24) would be likely
to identify an impact on locally sensitive sites, we would suggest that a further consideration should
be given as to how the Council anticipate this standard might be delivered, noting that the direct
application of this standard to the Site would require an additional area of 3.36 ha of Greenspace to
be provided.
4.3 Such a requirement in addition to the existing land take to meet open space standards, on site SUDs
and on site BNG, would result in a significant reduction in the current housing potential, making the
current policy proposal for 175 dwellings unrealistic. This standard may also have a serious impact
on the viability on this Site and other similar proposed allocations
4.4 Furthermore, sites in Colchester do of course make RAMs contributions to seek to manage
recreational disturbance pressures, so again, this is a factor that should be taken into account
alongside the Natural England ratio which may not consider local factors such as this and effectively
result in double counting in conflict with the CIL Regulations.
Sustainability Appraisal Report (February 2025)
4.5 Both the Site and the wider allocation (PP24) have been considered within the evidence base
documents to the emerging Local Plan, including the Sustainability Appraisal Report (February 2025)
(the SA) which assesses whether the emerging Local Plan will help achieve sustainable development
when compared with reasonable alternatives.
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4.6 The SA confirms that Wivenhoe is a sustainable settlement and has good infrastructure provision
and is one of the four largest towns beyond the City of Colchester. However, it also indicates that the
proportion of growth directed to Wivenhoe and West Mersea is lower than the other two larger
settlements of Marks Tey and Tiptree owing to the internationally important biodiversity
designations.
4.7 At Table 5.36, a summary of the SA findings in respect of Policy PP24 is provided and expanded upon
at Paragraphs 5.323 to 5.329. It is considered that this provides a fair assessment of the Policy based
on the existing evidence base. It is noted that the conclusion is that no recommendations are
proposed for any changes to the Policy. In respect of the assessment, some of the areas where
negligible effects have been recorded, for example in respect of the historic environment (SA
Objective 7), Biodiversity and Geodiversity (SA Objective 8) and Landscape (SA Objective 9) a higher
score may well be achieved following the completion of the Site specific technical assessments
currently being undertaken by the Promoters, which will provide further detail and clarification on
the potential positive mitigation which can be delivered.
4.8 In conclusion, it is considered that the SA provides a robust assessment of the proposed allocations
and polices in the emerging plan. It has considered a comprehensive range of reasonable
alternatives, identified suitable and relevant options, and as such, is supported.
Summary of Sites Evidence (October 2025)
4.9 As part of the evidence base for the emerging Local Plan, the Council have produced a Summary of
Sites Evidence (October 2025) which contains a summary of the sites assessed as part of developing
the new Local Plan for housing and employment. These sites were collated via a ‘Call for sites’
exercise or a desktop review, with sites then assessed using the Strategic Land Availability
Assessment (SLAA). The Summary report also confirms that in bringing forward site allocation
choices within the Preferred Options Local Plan, other evidence base documents were used to
inform the suitability of sites.
4.10 The Site is considered under the name ‘Land North of the Fire Station’ Wivenhoe (Site Ref: 10755)
along with the other site submissions for the settlement. As part of the assessment the submitted
Site has been extended to include the ‘Care Home Land’ to the south. This amendment is supported
by the Promoters, however as referred to above a further modest increase in the site area as
discussed above and identified on the red line plan at Appendix A would also be beneficial.
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4.11 While the assessment acknowledges that the proposed allocation encroaches into the coalescence
area designated in the Wivenhoe Neighbourhood Plan, it helpfully acknowledges that the
encroachment is less than other proposals. It would be useful if the assessment were to highlight
that the allocation does not extend any further north along Colchester Road into the coalescence
break area than the northern boundary of the existing settlement around Feedhams Close on the
west side of Colchester Road when this report is updated next. It will also be necessary for it to reflect
the revised red line plan included at Appendix A.
4.12 The assessment also helpfully acknowledges that:
“The site is adjacent to one of the neighbourhood plan allocations and development can
be planned to complement that development, including delivering some of the homes
allocated on part of the existing allocation set aside for a care home, which is no lon ger
needed owing to the proposal for a care home on an alternative site in Wivenhoe. Access
can be made to the allotments to be delivered as part of the existing allocation
(currently with outline consent).”
4.13 This clarification is supported and considered helpful.
Emerging Allocations Biodiversity Assessment
4.14 The emerging allocations biodiversity assessment has undertaken a review of the proposed
allocation which is set out on page 60 of the report. The harm scoring is noted as:
“Little/no harm – the site has limited natural habitat value”
4.15 This assessment is supported and the general commentary is considered to be a fair reflection of
the Sites biodiversity value and potential, having regard to the site-specific ecological, arboricultural,
and landscape technical work which has recently been completed by the Site Promoters.
Heritage Impact Assessment Sift (January 2025)
4.16 The Heritage Impact Assessment Sift Methodology (January 2025) was a desk-based assessment of
each site to identify any heritage assets with the potential to be affected by their allocation. Following
the sift, three levels of further heritage impact assessment are recommended depending on the
potential impact of the allocation of a site on the historic environment. These were categorised as:
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• No further assessment: (the allocation of the site has been assessed to have no effect on the
significance of any heritage assets);
• Proforma Heritage Impact Assessment; and
• Detailed Heritage Impact Assessment.
4.17 The Land North of the Fire Station was assessed to fall within the first category, no further
assessment required and this conclusion is supported given the limited proximity of the nearest
designated heritage assets.
4.18 It is acknowledged that the site assessment indicates that a heritage statement will be required to
inform the layout of the site and scale of development, given the listed buildings in Colchester Road.
It is also noted that the assessment indicates that a desk-based archaeological assessment will be
required, potentially supported by trial trenching.
Colchester Infrastructure Audit and Delivery Plan, October 2025 (IADP)
4.19 The IADP at Table 2-3 indicates the planned housing growth over the plan period, for Wivenhoe
years 1-5 there are 175 houses planned. The opportunity for the Site to come forward early in the
plan period is supported and its ability to contribute fully to the Council’s ability to demonstrate a
five year housing land supply at the point of adoption is welcomed. As referred to elsewhere in this
consultation response, the Promoters are actively working towards the submission of an outline
application later this year (2026) to ensure that this delivery timetable is not delayed.
4.20 The above further demonstrates the suitability, availability, and deliverability of the Site for
residential development.
4.21 Appendix A of the IADP at Project ID 159 Transport, under Active Travel identifies the Wivenhoe
Mobility Hub as Phase 2, delivery 2029-2033, at an unfunded cost of £506,880 and continues under
the Funding Sources
Funding not secured. Developer funding expected from S106 and/or S278. Potential grant funding
routes include BSIP and LuF Proposed Funding Split - 100% contribution from preferred
allocations - 0% contribution from reference case developments - 0% contribut ion from external
grants.
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4.22 Clearly this a project which will not only benefit the future occupants of the Policy PP24 allocation,
but also the existing residents of Wivenhoe and the wider area. From the table it is unclear which
allocations are expected to contribute to this particular infrastructure upgrade. Having regard to the
CIL Tests what the reasonable and propionate financial contribution would be expected from the
development allocations, it is assumed that the reference to ‘0% contribution from reference case
developments ’ means this will be pooled contribution and a modest contribution is that would be
expected as a from development of the Site (Policy PP24).

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5. CONCLUSION
5.1 Manor Oak Homes and Mr Charles Gooch welcome the proposed inclusion of the Land Northwest
of the Fire Station as an allocation in the emerging Preferred Options Local Plan and support the
inclusion of Policy PP24 in the Plan. They welcome the opportunity to work with Planning Officers to
further refine the Policy and ensure that the Site is both a developable and deliverable housing
opportunity and can be delivered in in the early part of the plan period, helping the Council
demonstrate a five year housing land supply upon adoption.
5.2 Wivenhoe is a sustainable settlement and is one of the four largest towns beyond the City of
Colchester and an appropriate location to direct development in accordance with the Council’s
proposed development strategy which is supported along with the robust approach adopted by the
Sustainability Appraisal.
5.3 The draft Plan confirms that Wivenhoe benefits from a good range of infrastructure, including a
mainline train station, GP surgery, two primary schools, numerous shops and restaurants, and
abundant open space provision. It also benefits from public transport connections to Colchester
and a good cycle and footpath network which provide good connections to the University of Essex
amongst other destinations. As such, the Town can be acknowledged as a sustainable location, in
line with the Plans development strategy for the accommodation of further growth. This is
welcomed.
5.4 It is the Promoter’s intention to work up a formal pre-application submission to help further develop
the details of the Site proposals ahead of the potential submission of an outline application later in
the year, which will help to confirm that the Site is developable and provide a clearer indication of
when housing delivery will be likely to commence.
5.5 The Promoters consider that this represents an exciting opportunity for them to deliver a high
quality housing scheme which responds to the established environmental character of the
settlement edge and provides a range of modern homes in a beautiful, green, and sustainable
location, to meet the needs of the growing local community. Delivering a development which will
foster a strong sense of community and promote healthy and sustainable life styles, with a lasting
legacy and sense of pride, is a key objective.
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5.6 While this represent includes some relatively detailed commentary in respect of the particular
criteria and wording of Policy PP24, these are not intended to be a criticism, but a positive review to
assist the Council with the drafting of the forthcoming version of the Policy and supporting text to
be included in the Regulation19 submission version of the Plan, to help ensure that the Plan can be
found sound on examination with limited modification.
5.7 In summary, the Promoters support the Plan and Sustainability Appraisal along with the Council’s
assessment that the Site is suitable, available, and achievable within the plan period. Its early delivery
will also strengthen the Plan’s housing trajectory and the future five year housing land supply. This
representation supports Policy PP24 subject to the recommended refinements to the wording
recommended in Section 3 above and captured in track changes version of the Policy included at
Appendix B, as well minor amendment to the Site area (increased to 8.828 hectares) as indicated in
the Plan at Appendix A.
5.8 Inclusion of these amendments will help to ensure flexibility, clarity, and this representation aims to
confirm the deliverability of the Site in the early part of the Plan period.
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Appendix A - Revised Site Plan (Red Line) – SLP-01 P4
Proposed Amended Site Area


Revised Site Area Approximately 8.828 hectares

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Appendix B – Recommended Amendments to Policy
PP24
Policy PP24: Land Northwest of the Fire Station, Wivenhoe
In addition to the infrastructure and mitigation requirements identified in Policy ST 7 and subject to
compliance with all other relevant policies, development will be supported on land within the area
identified on the policies map which provides:
a. Approximately 200 new dwellings of a mix and type of housing to meet evidenced needs and be
compatible with surrounding development;
b. Safe and suitable site access to required highway design standards and point(s) of vehicle access
to be via the adjoining Neighbourhood Plan allocation, to be agreed with the Highway Authority
and demonstration that the proposal would not be detrimental to highway capacity or safety;
c. Provide a safe pedestrian and active travel access to ensure connectivity within and throughout
the site and to the settlement and surrounding area. Connections to existing footways and the
track to the allotments and where possible recreational access to the countryside should also be
considered. to existing footways and any Public Rights of Way. Ensure provision of green
infrastructure connections and recreational access to the countryside, also securing active travel
links and connections to the settlement;
d. Contributions towards enhancement of the quality and value of King George V Playing Fields;
e. Screening comprising locally appropriate tree belts and/or hedgerows will be required along the
site boundaries to ensure that development is sensitively integrated into the landscape and to
maintain settlement separation;
f. Biodiversity enhancement measures should include enhancing hedgerow condition and
establishing grassland habitats along road verges;
g. Development must conserve, and where appropriate, enhance the significance of heritage assets
(including any contribution made by their settings). Designated heritage assets close to the
allocated site includes five Grade II Listed Buildings as informed by the stage 1 HIA;
h. The total number of dwellings will be spread between this site and the area currently set aside
for a care home as part of the neighbourhood plan allocation;
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i. A new community space must be included within the site and pedestrian access to the adjacent
allotments must be created;
j. Opportunities for undergrounding should be explored;
k. Development must discharge attenuated surface water to a receiving waterbody and not to the
combined sewer network, unless it can be demonstrated that there is no other option.
l. Demonstrate adequate capacity for managing wastewater including proposed phasing
requirements or alternative solutions to the satisfaction of the Council and Anglian Water;
m. A range of measures in addition to prioritising SuDs (Policy EN8) and water efficiency measures
to reduce the risk on impact on the WRC capacity as a result of planned growth including:
i. Removal of unrequired network flows;
ii. Targeted education to include new residents of the development;
iii. Reduction in the demand for potable water.
n. Any site specific infrastructure requirements from the IDP (likely to include education provision,
highway mitigation, water and wastewater and specific community / open space provision).
o. Before granting planning consent, wintering bird surveys will be undertaken at the appropriate
time of year to identify any offsite functional habitat. In the unlikely event that significant numbers
are identified, development must firstly avoid impacts. Where this is not possible, development
must be phased to deliver habitat creation and management either on or off-site to mitigate any
significant impacts. Any such habitat must be provided and fully functional before any
development takes place which would affect significant numbers of SPA birds.
All development Proposals within Wivenhoe Neighbourhood Plan Area, will also be determined against
the policies in the Wivenhoe Neighbourhood Plan (Adopted May 2019) where they are up to date and
relevant.

Wivenhoe Town Council response to CCC Local Plan Reg 18 consultation – January 2026

Contents

Background
Site specific comments
General comments
Biodiversity impact
Biodiversity significance
Comments on biodiversity site selection
Transport
Viability
Employment
Comments on the wider Local Plan
Conclusion

Background.

This background is intended as an introduction for members of our community with no prior knowledge of the planning system. The Wivenhoe Neighbourhood Plan (WNP) is current, adopted policy of both WTC and CCC.

Both the WNP and the citywide plan, the Local plan (‘LP’) must be reviewed every 5 years. Both are current policy.

A Neighbourhood Plan is produced independently of the LP process by local groups. They can receive an overview from CCC to ensure they align with the LP.

The decision not to review the WNP before the site allocations was announced was the right one because a reviewed NP will have to be adopted by the city council. However, we do not have to accept what has been put forward by the city council.

Both the NP and the LP must comply with the National Planning Policy Framework (NPPF). It should be noted that national policy has changed since the current NP and LP were created.

The Reg 18 consultation is the opportunity to respond to site allocations and all other aspects of CCC’s draft proposals in order for appropriate changes to be embedded prior to the reg 19 consultation. This can involve changes to draft policy and site allocations.
Once the LPA is satisfied that the local plan is ready for examination it will conduct the reg 19 consultation which is done on behalf of the Secretary of State, who will appoint a government inspector to test the plan’s soundness. These are:
Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence.
Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.
Developers can also use the reg 19 consultation as an opportunity to put forward additional sites. This is when the site at Middlewick was introduced to the current local plan last time.
WTC does not believe that the current iteration of the emerging LP meets the soundness test, primarily because it does not meet with national policy, in part because the infrastructure assessment is flawed (it does not account for the negative impact of the TCBGC on Wivenhoe and the viability is at best highly questionable) and in part because it is not justified in a local context.
Site specific comments (on 10756 - Land North of the fire station)

This site provides a separation from other settlements, views towards the river, and across green fields.

Criteria (not exclusive) by which it fails the SLAA assessment are: -

• The sites are outside the existing settlement boundary, breaching policy WIV 14.
• The university have a proposal to fill the whole of the Coalescence gap with solar panels creating policy non-compliant coalescence.
• The site would have to directly access the main arterial road through Wivenhoe: Across the cycle lane which we are trying to encourage more use of.
• The site is Greenfield.
• It is Grade 2 agricultural land.
• The site is approximately 0.5km from a registered park land (Constable country) and will be visible from it.
• The site is within a Minerals Safeguarding Area.
• The site is within the Coalescence Breaks (WNP policy WIV4) See figure 1 and 1 a
• The site overlaps the River Colne Special Character Area. See figure 2 and 2a
• The site is constricted for development because of overhead pylons. See figure 3


Fig 1 Fig 1a



Fig 2


. Fig 2a




Fig 3


Additional issues with this allocation include, but are not limited to
• The green buffer does not carry round the whole of Wivenhoe which is our stated preference – see Figure 3 picture b – area 2 and 8 should join via the ‘Wivenhoe Landscape area’ and the ‘Wivenhoe borders’. The Wivenhoe Plan for Nature, which informs our Wivenhoe Neighbourhood Plan, goes into greater detail on the desperate requirement for a green corridor and is supported by third party environmental reports (which we can share on request)
• Wivenhoe has a train station, is on a major bus route and has enhanced cycle provision. In principle one of the best places for modal shift, yet it has not achieved any measurable success. Despite being one of the best places in the sub-region to establish modal shift it has not, and never will improve as there are no local jobs, local pay is low on a national scale and school places are short – more cycle provision will never fix these fundamental issues and 50% modal shift is self-evidently unobtainable.
• Buses in this corridor (and the wider context of Wivenhoe to Colchester and beyond) will always be slow and unpunctual at the very times when modal shift is most desired.
• Whole project viability is of grave concern. These concerns are not limited to the 100’s of millions of unfunded infrastructure elements in the viability assessment. Specifically, the only additional funding earmarked for Wivenhoe we can find appears to be for a mobility hub. S106 funding will need to be tailored for infrastructure we need, not what ECC want. Considerably more research needs to be done by WTC regarding this element but it is not an area of focus before the reg 19 consultation.
• The five-year review of WNP plan is on hold until this allocation is justified, creating longer term policy issues.
• The strategic biodiversity sites must be accounted for within the Wivenhoe Plan for Nature which is an emerging policy document within the WNP framework.

General Comments

Wivenhoe’s Neighbourhood Plan allocates sites for housing until 2033. These sites were based on sound evidence and this plan has been adopted as policy by Colchester.

Our NP established, as evidenced in policy, that there is insufficient infrastructure to sustain any additional homes, above and beyond the 250 new dwellings proposed in 2016. Even if it was reasonable to acknowledge the 41% uplift in housing numbers introduced by government, this should only take our existing allocation of 250 up by 102 and not 175.

The unused care facility land at the existing Cala Homes site is designated as employment land by WTC. It is viewed as a windfall site for the NP post 2033 and should not be considered in the LP.

The current situation is that there is no possibility of expanding existing infrastructure, either practically or financially to build more than the 250 allocated (now mostly built) in the current plan. E.g.:
• There is not sufficient employment within the town, and the plan offers no employment sites. This plan must reflect diminishing jobs at the University of Essex and the likely failure of the Knowledge Gateway in the context of the inability of the University to expand.
• Greater Anglia do not plan to improve the frequency of trains and commuter trains are almost always full past Colchester. We also have insufficient parking near our conservation area located train station.
• The A133 has been identified as the city’s most restricted route into the town. There are no guarantees the link road will arrive to alleviate this or even if it will hold the additional capacity required to service the traffic generating scheme of the TCBGC.
• All local primary school years are full following the development created by the NP. This does not factor in that the TCBGC will not receive a primary school for many years and ECC intend to use Wivenhoe’s stretched to capacity schools for early TCBGC residents (see purpose of school streets scheme)
• The bus service is limited, and crucially made slower and less desirable, by destinations and the increased congestion along the routes. 25 years ago, the bus took 15 minutes to Colchester town centre. The bus station to the Co-Op is now 24 minutes on the 87 and 32-52 minutes on the 51. We fail to see how this can be sold as an improvement to encourage modal shift.
• There are no NHS dentist places between here and the coast.
• There will soon be pressure from the new town on all our services and facilities. We have very limited capacity in our GP surgery (enough for the current NP only) but the new town will be within our GP’s catchment. NB Our GP surgery is in the conservation area and has no parking and constrained access.
• We have an acute shortage of playing fields for our own local clubs, however, there is no timescale for the university or the new town to build additional facilities. CCC LP’s have maxed out Wivenhoe’s infrastructure – in short there is nothing more for you to take.
• The nearest secondary school is over 2km away and we have heard examples of our preferred school (the Colne) turning students away even when they have siblings already attending.
• The five-year review of WNP plan is on hold until this allocation is justified, creating longer term policy issues.
• The strategic biodiversity sites must be accounted for within the Wivenhoe Plan for Nature which is an emerging policy document within the WNP framework.

Biodiversity impact/economic opportunity/strategic context
The town’s emerging Nature Plan identifies the natural resources surrounding Wivenhoe as a mosaic of habitats surrounding the town. Each on its own is a crucial resource for wildlife; each is a component of the town’s rural character.
Together they create a strategic wildlife corridor.
This assemblage of habitats reinforces the social and ecological benefit of the existing coalescence gap.
It uses the planning concept of “strategic green gaps” to establish “coherent ecological networks that are more resilient to current and future pressures.” (from the NPPF)

All sites lie within the Zone of Influence for the Colne Estuary SPA and RAMSAR sites about recreational pressures.


Site specific Biodiversity significance
• Migration route and daily corridor for birds to/from the Colne flyway and feeding grounds: (birds of prey, waders & wildfowl).
• Fields host breeding Skylarks, fields and hedgerow host Cetti’s Warbler (schedule 1 species) and Nightingales (suspected breeding in 2021).
• Mature hedgerows provide foraging/transit for bats (includes European protected Barbastelle, recorded in neighbouring site summer 2023) and important land-based connectivity features across the length of the town’s Coalescence Gap.
• Margins hold populations of Common Lizard
• Rich abundance and diversity of wildflowers and rare specialist plants including Fleabane.
• Potential return of Turtle Doves (schedule 1 recent breeder).

Comments on selection for strategic biodiversity sites

We warmly welcome the selection of these strategic biodiversity sites. We have been working, via the WNP, the Planning Committee, the Plan for Nature and our Environment Committee to protect these vital habitats and we wish to make it clear we wish to work with CCC to continue to enhance these habitats. It is critical to the biodiversity, and the success of these sites, that the nature corridors are managed and not destroyed by the housing site allocation. This is noted above under site specific comments but repeated here for context, the green buffer does not surround the whole of Wivenhoe which is our stated preference – see Figure 3 picture b – 2 and 8 should join via the ‘Wivenhoe Landscape area’ and the ‘Wivenhoe borders’.

Colchester City Strategic Biodiversity Assessment - Area - 8. 5.36 to 5.38.
Between the eastern edge of Wivenhoe and the City border is a buffer of land with existing or potential value for biodiversity. At the southern end, to the south of the railway line, is part of a large block of coastal grazing marsh within the Upper Colne Marshes SSSI, which provides a link to the Roman River Valley (Area 1) and the River Colne (Area 2).
Between the railway line and Alresford Road, the valley slope of the Colne estuary is currently under arable cultivation, but sits on a superficial deposit of Kesgrave sands and gravels that would make it particularly suitable for habitat creation measures aimed at acid grassland or open mosaic habitats.
North of Alresford Road is Wivenhoe Pit, from which the same Kesgrave deposits (and others underlying them) have been extracted. This area is now a varied landscape of woodland, grassland scrub, lakes and open mosaic habitat with considerable biodiversity value. The older part of the site is designated as Co161, but most is not currently managed with nature conservation in mind and so there is opportunity to enhance the distinctiveness and condition of some of the habitats.


Sites of special scientific interest and local wildlife sites

Figure 2, Designated nature conservation sites in Colchester, is a clear visual aid to understanding that Wivenhoe is surrounded by significant nature assets (including woodland and river as well as SSSI and LoWs) and that there is no space for houses and nature corridors. We believe, and can demonstrate, that these sites are equally as biodiverse as Middlewick and they are certainly as important to our residents.
Viability
There is an estimated £400 million shortfall in the viability of the LP. It remains unclear how this affects Wivenhoe. The value accrued by the selected site in s106 would be radically less than what would be required in terms of infrastructure uplift given the infrastructure deficit in Wivenhoe as described across this submission.
Transport
The LP aspiring to 50% modal shift is just an expedient as it is the only way you can massage the traffic figures and we are bored of pointing out why it will not work. We will not dwell on it here as throughout the planning process for the last local plan we pointed out its myriad flaws. The rate of cycling to work in Colchester peaks at around 2% in the summer yet ECC\CCC have been working on modal shift for a decade. It is clearly not a success. We want to know why a back-up plan or backstop for when modal shift inevitably fails is going to be seriously discussed as this policy condemns Colchester to ever worsening gridlock.
Driving out of Wivenhoe at or near peak times only serves to add traffic to the already highly congested Clingoe Hill\A133. The burden of existing and planned overdevelopment has more than accounted for any capacity perceived to exist in a desktop study.
Buses
Buses are slowest when they are most needed, at commuting times. Morning travel times between the middle of Wivenhoe and Colchester can take over 50 minutes. Buses only serve Colchester and outlaying employment areas either cannot be reached or require changes.
Cycling
WTC Travel & Transport Working Group have added the following comments.
Colchester is surrounded by very dangerous major roundabouts on all sides. There is no East-West cycle route through the town centre. Until these fundamental issues are resolved (as they have been in Chelmsford, Norwich, etc, etc) cycling will remain an unattractive option.
The LP admits that walking to work, college, etc, will not be an alternative option for most drivers.
Employment
The new residents are not buying £400k-plus two bed houses on local wages – they are almost all existing commuters from beyond Colchester and most by road – the houses will add additional car journeys through to the A133 and Colchester. It is not uncommon to find residents who drive to London to work as the train is too costly and largely impractical. These houses are not for existing local residents – most are sold by developer campaigns in London and along the A12.
There is very limited provision for employment in Wivenhoe and we urge you to consider the impact that hundreds of forecast job losses at the University will have on Wivenhoe – these will not be replaced with local jobs and residents will be forced to seek work further away and most likely travel by car.
Our NP factored in two employment sites (both care facilities) and one was not delivered.
The wider LP seeks 21,000 new jobs over the plan period. With AI, automation, the A12 being recognised as the worst road in the country and the failure of the Government to fund the widening scheme, the over expansion and subsequent decline of the sub-region’s biggest private employer – the University of Essex- this is simply absurd. Colchester City Council promised one job per house at the TCBGC – their track record in this area will never engender confidence.
We wish to reiterate that it makes more sense to build at high density near the A12 rather than forcing additional traffic though Colchester from the Tendring side.
Comments on the wider Local Plan
The Local Plan will fail, as the last one did with the botched attempt at creating three new towns, if it does not accept reality. We note that new towns were CCC’s vision of the future of strategic planning until you got one. With no little irony or vindication, we note that they have admitted this failure by not even considering a new town in this local plan. We urge CCC to learn the lessons from the abject failure of over promising and under delivering that dogged the last local plan, we especially wish to reference the clear divide with reality and this iteration.
Conclusions
Whilst we are broadly content with the strategic biodiversity sites, we strongly object to any additional housing being allocated to Wivenhoe. The allocated site does not meet with local policy nor is it consistent with national planning policy. It is not justified. It does not meet with the WNP and it hinders the progress of future iterations of the WNP. It must be removed ahead of reg 19. We note that Tendring have the courtesy to not allocate housing numbers to Elmstead Market and they state this is because of the negative and unsustainable effect of TCBGC on existing community infrastructure. That courtesy must be extended to us, especially when viewed through the prism of consistency when the two councils are set to be merged via LGR.
We remind Colchester City Council that this response must always be held in the context that we have the traffic generation scheme at TCBGC, which will leech our amenities, greenspace, road space and infrastructure.
These site-specific policy inconsistencies are laid out on page 5. We draw your attention particularly to our ‘village envelope’ and we remind you that WTC have always considered this to be our red line as we have a long-standing fundamental aim to ensure against coalescence.
Wivenhoe is surrounded by the natural break created by the A133, our coalescence break, a river, SSI sites, LOWS, roman woodland and rules around our conservation area and sites of historical importance. There is simply no room left for this level of development and what little there is must be reserved for the WNP, for example the Cala Homes windfall site cited above.
The general site comments, on page 4 highlight how the plan is not justified nor positively prepared and this is further evidenced with comments on additional issues on page 10. This is not an exhaustive list and we retain the right to draw on these matters and others, should we need to represent ourselves at the reg 19 hearing.

The requirement in criterion d) to seek contributions towards King George V Playing Fields is welcomed as enhancements to the capacity of this facility would be appropriate for meeting the additional needs generated by the development. However, consideration should also be given to contributions being used towards enhancements to the Broad Lane Sports Ground as the Council’s Playing Pitch Strategy and sports governing feedback has identified this as another priority project in the Wivenhoe area. 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.

My partner [REDACTED] and I have read in full Wivenhoe Town Council's 10 page response to this and we consider it a sound and robust rebuttal to any suggested viability of 175 homes on this site. We wholeheartedly agree with all their points raised in objection. We also agree strongly, that, just as Tendring has not allocated further housing numbers to Elmstead Market in recognition of the negative and unsustainable impact of the new garden city development on existing community infrastructure, that Colchester City Council should afford a similar dispensation to Wivenhoe.
[REDACTED]

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 attached

See Full Submission attachment

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.

Walk Wheel Cycle Trust (formerly Sustrans) would like to submit a response to the Preferred Options Local Plan consultation in regards to National Cycle Network (NCN) Route 51 which connects Colchester and Wivenhoe.

The National Cycle Network is a UK-wide network of signed paths and routes for walking, wheeling, cycling and exploring outdoors. We work with partners and professionals across the UK, helping them to make walking, wheeling and cycling an easy and safe option for more communities up and down the country. Together, we're moving towards our vision of a traffic-free, more consistent and accessible Network for everyone.

NCN 51 – also known as the Wivenhoe Trail – is a well-used walking, wheeling and cycling route which runs between Colchester and Wivenhoe on a traffic free greenway between the River Colne and the railway.

The majority of this path is formed of two public footpaths – Footpath 130 Colchester and Footpath 8 Wivenhoe. A small section (approx. 180 metres) of the NCN is off the footpath alignment, as shown on the images below*, as the original footpath alignment has been lost to erosion following a breach of the sea wall Public access to this section, as well as consent for cycling along the length of the Trail, is subject to landowner permission for which considerable premiums have been paid.

Securing long term rights for walking and cycling
Walk Wheel Cycle Trust have ambitions for long term rights for cycling (as well as walking) to be secured along the Wivenhoe Trail, in line with our aspirations to secure legal rights for the public to walk, wheel and cycle on more of the NCN. The mechanism we believe this can be achieved is through:
- Creation/upgrade of the route to a bridleway or cycle track; or
- Transfer of the land to Local Authority ownership

Securing public access rights in this way improves the funding prospects of future path upgrades by offering security on the investment of public funds.

Policy PP24: Land Northwest of the Fire Station, Wivenhoe
Some of the Wivenhoe Trail is under the same ownership as site allocation Land Northwest of the Fire Station, Wivenhoe, which is included in the draft Local Plan as Policy PP24. Policy PP24 states that for residential development to be supported on the site (amongst other things) it must:

“c. Provide a safe pedestrian access to ensure connectivity within and throughout the site to existing footways and any Public Rights of Way. Ensure provision of green infrastructure connections and recreational access to the countryside, also securing active travel links and connections to the settlement”

NCN 51 will be an important asset to residents as it is an obvious and enjoyable active travel link from the site into Colchester, and provides recreational access to high quality green and blue infrastructure. The NCN can be accessed from Land North of Fire Station via residential streets and Footpath 7 Wivenhoe. PP24 should specifically refer to the Wivenhoe Trail/NCN 51 and seek to improve the route and connecting PROW. The map below* shows the Trail in relation to the site allocation.

The same principles would apply to other current or future site allocations in the vicinity.

Should this policy be adopted with a reference to the Wivenhoe Trail as suggested, Walk Wheel Cycle Trust would support this site allocation, given its benefits to the NCN.

Other aspirations for NCN 51 and connections
As well as securing the land for public and active travel access, the Wivenhoe Trail/NCN 51 and connecting paths would benefit from maintenance and improvements to the path surface and drainage, to support the year-round usage by a wide variety of users.

Improvements to the surface and maintenance of Footpath 7 Wivenhoe and Footpath 236 Colchester would further uplift active travel in the area. Footpath 7 provides access between the site and the Trail via Lower Lodge Farm/Colne Local Nature Reserve. Footpath 236 Colchester connects the Trail to the University of Essex campus, and also forms part of the same land parcel and ownership.Maintenance and surface improvements to these paths would ‘ensure provision of green infrastructure connections and recreational access to the countryside’ in line with Policy PP24.

Our asks for the new Local Plan
Walk Wheel Cycle Trust request that the Local Plan seeks to identify any opportunity to
a) Secure long term rights for both cycling and walking along the Wivenhoe Trail
b) Help facilitate investment in maintenance and improvements of the Trail and connecting PROW to ensure a high-quality, inclusive and accessible active travel route
c) Include a requirement for development proposals to invest in maintenance and improvement of walking and cycling networks, including the NCN and specifically referring to well-used routes such as Wivenhoe Trail

For example, PP24 could be more specific in its requirements for active travel links by referring specifically to the Wivenhoe Trail and requiring the creation of a bridleway or the transfer of land ownership.

Policy PC2: Active and Sustainable Travel could specifically refer to the NCN and well-used routes such as Wivenhoe Trail and require new developments to contribute to their maintenance and improvement. Otherwise, Walk Wheel Cycle Trust support the inclusion of Policy PC2 and the reference to LTN 1/20 standards.
MAP UNABLE TO COPY- TITLE: NCN 51 from Wivenhoe to Colchester, in context of Land North of Fire Station and local public rights of way