With regard to the proposed changes to the local plan, whilst I understand that future housing targets have to be met, it is of course important that they are located where they would cause the least disruption to existing residents and with the most convenience to all.

To this end I am commentating in respect of Copford in particular.

It is vitally important that the local environment and character of the area are preserved. This would include among other things maintaining the separation of local parishes and the retention of the local countryside.

The proposal is for a large number of houses to be built in the Marks Tey area - approximately 1500 South East of the A12 (behind Marks Tey shops), of which 600 would be within the Copford boundary and 300 along School Road and either side of the village hall.

Prime Farmland

Most, if not all, of the land proposed for housing is good quality, productive farmland. It is very shortsighted indeed to destroy this by using it for housing when there are other areas that could be developed. It is clear from events in the news and as evidenced by the war in Ukraine, that we should be producing as much of our food as possible in the UK, preferably locally. Large areas of farmland have already been taken for the solar farm, so we must preserve what we have left.

Traffic

Traffic is a major concern. The A12 and A120 are both heavily congested, with daily queues along the A120. These have the inevitable consequence of bringing the roundabout where the A120 joins the A 12 at junction 24 to a standstill, making it

Page I 1difficult to leave the A12 from the Northbound carriageway. As it is reasonable to assume that many of the new households will want to travel to and from work along the A12 and/or A120, we can roughly estimate that the proposed new homes would bring another 1800 - 3600 cars into the equation (and that's without adding in the additional traffic from the other houses proposed in the area north of Marks Tey).

In addition to the congestion, we have to also consider the safety aspect, as the are constant (almost daily) accidents up and down the A12.

There was a proposal for widening the A12, but this has of course been scrapped. If this work on the A12 was considered necessary for even the existing housing, it is difficult to see how these roads would cope with the level of new homes proposed for the Copford area.

Anglian Water

I understand that the infrastructure, both with regard to the provision of clean drinking water and the processing of sewerage is pretty much at capacity. Further, we are told that there is no funding in Anglian Water's current 5 year plan for upgrades to the local infrastructure. Seemingly then, it will not support such a large number of houses.

Other Local Services

It is apparent that there has been a significant decline in the access to services provided by local health providers such as dentists, doctors etc. This seems to be predominantly to be as a result of the increase in population that has already taken place, so serious consideration would need to be given to how and if they could cope with such a large population increase.

With regard to the proposed site at School Road in particular:

Pitts Wood

Pitts wood is a protected and extremely valuable ancient woodland and wildlife habitat. It is home to nesting nightingales - a species that has suffered a decline of over 90% in recent decades due to habitat loss. Whilst there may be a proposal for a buffer zone, this will not stop the inevitable noise, traffic pollution, light pollution and disturbance for an increased number of local residents walking through there, as would be their right to do. There would likely be an increase in the number of dogs which of course would further disturb the wildlife in the woods.

Traffic

Page I 2I have previously mentioned the effect on the A12 and A120. But in respect of the School Road site there are other considerations. The only viable access is probably onto School Road itself. This will lead to almost all the addition 300 to 600 extra cars trying to leave via the T junction with London Road. This is a junction that is already very busy and that entails pulling into or across heavy traffic along London Road. This leads to obvious concerns regarding congestion and safety. It is not an option for traffic to be routed the other way towards Copford Green. With regard to public transport, I don't believe there are any buses along School Road, so anyone with out a car would need to walk to London Road.

Alternative Sites I understand that Colchester City Council has targets to meet so, as houses have to be built, I think that we must look to build on land that is not prime farmland and in particular priority must be given to sites around that are unfarmed.

Conclusion In summary my primary concerns in order of importance to me personally are: 1. Detrimental effects on Pitts Wood and its associated wildlife. 2. Destruction of prime farmland. 3. Increased traffic and congestion.

I hope I have expressed my concerns adequately and that they, along with the concerns of others, can be taken into account in the next draft of the plan. Regards Mrs F A Read

Aldham Parish Council is concerned the allocation of some 3500 new homes in the seven parishes west of Colchester will represent a potential doubling in the population of this mainly rural area over 15 years. The decisions to allocate sites across this area appears to have been arbitrary and have been made without assessment of the cumulative impact on the communities and social infrastructure of these villages, including schools and access to GPs. Furthermore, this cumulative impact will have real effect on the principal traffic routes - A12, A120 and A1124 as well as numerous smaller rural roads that are used extensively as short cuts to avoid congestion and are in reality now part of the highway network, despite their inadequacy. This assessment of cumulative impact also needs to take into account emerging proposals for development on the east side of Braintree District which will further compound the problems. The City Council need to engage with our communities to reassure them that level of development proposed can be adequately mitigated by ensuring the emerging Plan is strengthened and improved before a Reg.19 Draft is published.

Hi we feel this development of three hundred houses on this site together with the six hundred on the other side of school road will more than double the size of copford village turning it into a town overnight. there are no plans for any infrastructure improvement i.e. doctors, dentists, schools, more importantly where is the sewerage going to be treated as the present plant cannot cope with the present numbers of properties. The entrance to the site is not very clear it will probably be sited by the village hall which will be hidden from the sight of vehicles coming down school road from london road because of the blind bend what on earth could go wrong. If this proposal gets passed we be grateful if names and faces could be made public as a village community will be ruined beyond repair.

300 additional homes into Copford will negatively affect the local countryside in the village, which has a prominent Red Kite population, amongst others. We have one primary school, limited shop options and restricted infrastructure. London Road is regularly at capacity, and continually negatively affected by Stanway/Stane Park, alongside continued increasing builds roadside. Nothing in the plan, beyond a not needed new town hall, supports vital infrastructure such as schools/doctors, for an area already having to use Stanway based infrastructure, which is already at capacity in most cases.

Aldham Parish Council is concerned the allocation of some 3500 new homes in the seven parishes west of Colchester will represent a potential doubling in the population of this mainly rural area over 15 years. The decisions to allocate sites across this area appears to have been arbitrary and have been made without assessment of the cumulative impact on the communities and social infrastructure of these villages, including schools and access to GPs. Furthermore, this cumulative impact will have real effect on the principal traffic routes - A12, A120 and A1124 as well as numerous smaller rural roads that are used extensively as short cuts to avoid congestion and are in reality now part of the highway network, despite their inadequacy. This assessment of cumulative impact also needs to take into account emerging proposals for development on the east side of Braintree District which will further compound the problems. The City Council need to engage with our communities to reassure them that level of development proposed can be adequately mitigated by ensuring the emerging Plan is strengthened and improved before a Reg.19 Draft is published.

I do not think that the number of homes proportionate to the size of the area. More than doubles the size of this parish. What plans are there to treat sewage as I’m not sure local sewage can cope. I do not believe that infrastructure and services will be delivered ahead of housing infrastructure, e.g Schools, GP’s, Shops, Dentists etc. Does the proposed development be in line with local housing needs?

On behalf of the landowner, The Angora Bare Trusts, the proposed residential allocation PP29: Land East of School Road, Copford is supported and we can confirm that the site is available and deliverable within the plan period.

Separate representations are being submitted by Welbeck Land on behalf of one of the other landowners, however, both parties are committed to bringing forwarded a comprehensive masterplan for the draft allocation. Preliminary discussions have also been held with Copford with Easthorpe Parish Council (owners of the majority of the land that lies immediately to the north of our client’s land), who are seeking to work collaboratively on this proposal.

As part of this representation of support and commitment to demonstrating deliverability of the site, an indicative Parameter Plan has been submitted to demonstrate key principles for development on our client’s parcel, which include indicative locations for development parcels providing a continuation of the linear settlement pattern fronting School Road, green infrastructure, blue infrastructure, open space and parking for the adjacent village hall.

The submitted Parameter Plan illustrates how the development could provide direct pedestrian links to the existing Public Right of Way (PROW) which runs parallel to the site. This would safeguard connectivity to the wider footpath network and support recreational access to the countryside and active travel connections, consistent with the draft allocation’s objectives.

However, as drafted and mapped, the allocation boundary does not fully encompass the land required to achieve criterion c. of the draft allocation policy, which seeks safe pedestrian connectivity to existing footways and any public rights of way. The accompanying PROW plan (drawing no. 4007778) demonstrates that the definitive alignment of the PROW adjacent to our client’s parcel to both the south and east lies slightly beyond the current allocation boundary as shown on the policies map. To ensure that future development can deliver compliant and direct links to the PROW network, the allocation should be extended marginally to reflect the correct position of the PROW and to enable deliverable connections to be designed and secured through the masterplanning process.

It is also proposed to provide additional connections to the existing playground and village hall, ensuring that existing community facilities and spaces are connected with the proposed development. As part of the key development principles shown on the indicative Parameter Plan, it is also proposed to update the existing footbridge to the north east corner of the site boundary, further enhancing integrated recreational links to the countryside.

A safe and suitable access to our client’s parcel can be achieved off School Road to the south of the village hall and a provisional access design has been prepared to demonstrate this.

Green buffers along the site boundaries will ensure that the development is sensitively integrated into the landscape and reflect the rural character of the area.

It is noted that criterion d. states:
“A replacement village hall must be delivered within the site, well connected to new homes and existing homes in Copford.”

Following informal discussions with Copford with Easthorpe Parish Council, it is understood that the existing village hall is held for charitable purposes, with legal title vested in the Official Custodian for Charities on behalf of Copford Village Hall. This ownership structure does not preclude change; however, proposals involving relocation, disposal or replacement of the existing village hall can be subject to charity trustee governance and compliance with charities law safeguards for dealings with charity land. In practical terms, this can introduce additional procedural steps and timing dependencies outside the direct control of developers.

Furthermore, Paragraph 98 of the NPPF expects plans to guard against the unnecessary loss of valued community facilities and to ensure established facilities are able to develop and modernise and are retained for the benefit of the community. In this context, a policy requirement for a wholesale replacement of the existing village hall is unnecessarily prescriptive where equivalent or improved outcomes could be achieved through the retention and improvement of the existing village hall.

To support the allocation’s effectiveness and timely delivery, it is therefore requested that criterion (d) is amended to provide appropriate flexibility as to how the village hall objective is achieved, without altering the overall quantum or intent of the allocation. Having informally discussed our proposal, the Parish Council has acknowledged the alternative option to retain and refurbish the existing village hall, alongside additional off-street parking provision (which could be accommodated on our client’s land, as shown on the indicative Parameter Plan) to help address existing congestion and on-street parking pressures on School Road at peak times i.e. school drop-off and collection, which is a known and prevalent issue in the village. This approach would secure tangible community benefit while reducing the risk of delay associated with a mandatory replacement solution. It is therefore proposed that criterion d. is revised to allow either replacement of the village hall or its retention/refurbishment with associated improvements, to be agreed through the comprehensive masterplanning process in consultation with the Parish Council and the hall trustees. Criterion d. could therefore be reworded as follows:

“A village hall solution to be agreed through the masterplanning process in consultation with Copford with Easthorpe Parish Council and the village hall trustees. This may be achieved either through (i) the delivery of a replacement village hall or (ii) the retention and refurbishment of the existing village hall together with associated improvements (such as enhanced parking provision).”

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

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

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

I object for the following reasons:
1. Pits wood will not survive with the additional 900 people. Have you consulted the woodland trust?
2. Additional traffic on a road which is not coping already.
No bus service in school road. It needs to be addressed
3. Sewage/ water needs to cope
4. School is not able to cope with addional pupils.
5. Doctor and dentist services need to be provided for so many addional people.
6. Village hall is already perfect but will not cope with addional people.
Lastly consideration must be given to preserve the peace of existing residents.

2021 census showed 680 homes in the rural village of Copford. An additional 300 homes would swamp the village and not be in keeping. PP17 proposes 1500 in Marks Tey of which about 600 are on Copford Parish land. This would see Copford increase from 680 to 1580 homes.
Would the car boot field not be more suitable, as it is within a 15 min walk of the station approximately 300 homes could go there. It wouldn’t ruin the village and would appeal to commuters.

I wish to submit a strong objection to the proposed development on existing agricultural land within our parish.
First and foremost, the infrastructure required to support a development of this scale simply does not exist. The Government has already shelved the long-promised A12 and A120 upgrades, leaving our area without the major road improvements previously cited as essential prerequisites for any substantial expansion. The local road network is already chronically congested, with daily gridlock at peak times. Developers have attempted to blame this on the pedestrian crossing near the train station, yet their proposed “solutions” consist merely of additional mini-roundabouts and further pedestrian crossings, which will only worsen traffic flow rather than improve it.
Secondly, the loss of productive agricultural land is wholly unacceptable. The UK already fails to produce enough of its own food, and removing even more high-quality farmland directly undermines national food security. This proposal would irreversibly damage an historic rural landscape, turning characterful villages into sprawling urban extensions with no regard for heritage, setting, or community identity.
In addition, the area is home to important wildlife, including birds of prey and dormice, which rely on the existing fields, hedgerows, and open habitats. Large-scale development would destroy or fragment these habitats, inevitably leading to a decline in these species. Such environmental harm is contrary to national and local commitments to protect biodiversity and natural ecosystems.
The claim that the area “needs” additional housing is unsubstantiated. Numerous nearby developments already have unsold or unoccupied homes, indicating that supply currently exceeds demand. Moreover, there are far more appropriate and sustainable ways to meet any genuine housing need, including:
Proper management of existing social housing stock, including addressing under-occupation and supporting households to downsize.
Ending the continual loss of homes through Right to Buy, which depletes affordable housing faster than it can be replenished.
Using compulsory purchase powers to bring long-term empty, derelict, or unused properties—including former business premises—back into residential use.
These options provide housing without sacrificing valuable farmland or damaging rural communities.
It must also be recognised that the proposed developments are not primarily serving local housing need, as many homes are marketed to buyers relocating from other regions, including London.
There is also a severe lack of public services to support such expansion. Essex Police has reduced officer numbers, raising real concerns about their ability to maintain safety for the current population. Increasing the population significantly without increased policing resources risks stretching capacity further and leaving Colchester vulnerable to the crime pressures typically associated with larger urbanised areas.
Another major issue is transport. Public transport in this area is both expensive and unreliable. Modern working patterns mean that many people no longer work standard Monday-to-Friday, 9–5 hours, nor do they work in locations easily accessed by public transport. As a result, public transport is not a viable option for most residents. The reality is that new households will almost certainly be car-dependent, with each property likely bringing at least two additional vehicles—often more, as many tradespeople now keep a work van at home. This will impose even greater pressure on an already inadequate road network.
Furthermore, the Council previously assured residents that development would not proceed if the A12 and A120 expansions were not approved. Those conditions have not been met, yet the Council appears willing to disregard its commitments in order to accommodate developer interests. The role of elected representatives is to uphold the interests of local residents, not to facilitate profit-driven overdevelopment.
Meanwhile, Colchester town centre continues to decline, with empty units and reduced footfall. Continuing to push large new developments into rural areas—rather than focusing on regeneration of existing urban spaces—will only accelerate this decline. In addition, there are insufficient local employment opportunities to support such a massive increase in housing, leading to higher commuting levels, increased congestion, and greater strain on already stretched infrastructure.
For all these reasons—insufficient infrastructure, the unnecessary loss of agricultural land, environmental damage, lack of public transport viability, increased car dependency, better alternative housing options, absence of local housing need, inadequate policing, harm to local character, and failure to honour previous commitments—I urge the Council to reject this application in full.

This close to Byways 24, 42 and 43 and BW 28. All need to be connected to network.

Copford village is an agricultural village with listed buildings and heritage. The proposal to introduce a further 300 homes is not in keeping with the local area or the neighbourhood plan, it is disproportionate to the size of the village. The addition of further housing will impact upon the local infrastructure i.e highways, schools, sewage, GP services and this does not appear to have been considered. There will be an impact upon the green space and habitats and utilises farm land which is actively used. what plans are in place for water and sewage which cannot cope already?

This policy is the proposed allocation to Copford. Reading PP29 in isolation would lead one to the conclusion that Copford’s allocation is 300 homes. This, though, is incorrect. In Policy PP17 there is a proposal to build 1500 homes on land South of the A12 which is described as ‘Marks Tey’. However a closer examination of this parcel of land reveals that it straddles both Marks Tey and Copford parishes. A rough examination of the size of the allocated site and the number of homes allocated to it leads to an estimate of approx. 600 of the 1500 homes being built within Copford Parish. This means Copford’s total allocation of homes would be in the region of 900.
However, given CCC’s recent refusal of a planning application in Tiptree because the proposed development straddles adjacent boundaries it would be reasonable to assume that CCC will follow its own precedent on this point and withdraw PP17 from the Plan. It would also help ease Junction 25 congestion.
Copford is part of Copford with Easthorpe Parish which comprises 3 parts; Copford (around London Road, School Road and Queensberry Avenue), Copford Green (a conservation area) and Easthorpe. At the 2021 Census the Parish had a population of 1725 with approximately 680 dwellings. The proposed allocation of 300 homes under PP29 would increase the number of dwellings by approx 133%. If 600 dwellings are included from PP17 the increase is 206%.
If we then apply an occupancy rate to the new homes of 3 people per unit there would be an additional 900 residents in the Parish (or 2700 if the 600 homes under PP17 are included). That represents an exponential boom in the Parish population of 152% (or 259% if PP17 is added). That is wholly unreasonable.
Copford Parish also has a Neighbourhood Plan (‘NP’). It was adopted in 2023 and I encourage the Plan Committee to read it. Page 4 states the NP seeks to:
“… conserve and enhance the distinctive nature of our rural community… by ensuring:
• The scale of growth and location of new buildings is proportionate to the size of the village….
• Opportunities are provided to actively favour ecologically sustainable building, including self-build and small developments with a low or zero carbon footprint...”
It continues on page 5 emphasising “...the absolute need for careful planning…”.
Objective 1 of the NP (page 6) seeks to ensure the Parish retains its “distinctive rural identity” and by Objective 3 seeks to favour small developments.
A 300 home housing estate on agricultural land in School Road is neither proportionate to the size of the Parish nor, given the character of School Road, a site that has been sensitively planned. If the 600 homes at PP17 are also taken into account the argument against becomes even stronger.

Complementary to the NP is the Parish’s Design Guidance and Codes prepared by AECOM and referred to in the NP. Page 36 of the AECOM document deals with School Road. It says development here should:
“… should maintain the continuity of built form along the main route. However, buildings should not be repetitive, and should provide variety of building types and design with coherent scale, massing and detailing.”

It continues, on page 37, that development in Copford should “...maintain the continuity of building line and the density and scale of development.” And, at page 45, it says:
“Any proposal that would adversely affect the rural nature character of the villages, or give rise to an unacceptable increase in the amount of traffic and noise would be inappropriate.”
Toward the end of the Code (pages 95-97) is a checklist for consideration of any new development. In my opinion the proposal at PP29 not only fails to satisfy any of the objectives or policies of the NP but it also fails to answer positively the majority of the relevant points and checklists in the Design Code.

The School Road site is also not a good allocation for other reasons. I refer to LUC’s Sustainability Report of February 2025. Table 5.40 (at page 423) contains a summary of its findings of the suitability of both the School Road sites (10226 and 10611) which straddle the Village Hall and are the 2 sites for the proposed 300 homes. The only positive finding from LUC appears to be the fact the houses will be built. In almost all of the other criteria considered by LUC, particularly SA2 and the loss of good grade agricultural land, the effect is negative. How, therefore can this allocation be good for this Parish?
I also rely on the content of a number of CCC’s own policies.
Policy ST7 – Infrastructure Delivery and Impact Mitigation which states:
“Permission will only be granted if it can be demonstrated that there is sufficient and appropriate infrastructure capacity to support the development or that such capacity will be delivered by the proposal. It must further be demonstrated that all necessary infrastructure will be delivered at an appropriate time to meet the requirements of the development, and that such capacity will prove sustainable over time in physical and financial terms.”
I am sure other residents of Copford will already have responded to PP29 on the question of infrastructure (and other matters) so I do not propose to comment in detail here suffice to say that the current proposals for infrastructure as a whole under this Plan are flawed.
Policy ST8 - Place Shaping Principles which states:
“All new development should reflect the following placemaking principles, where relevant:

…

e) Respond positively to local character and context to preserve and enhance the quality of existing places and their environs.”

A 300 home housing estate does not satisfy point (e).

Policy PC4 - Development Density which states:

“In particular all residential development will need to be at an appropriate density and massing, having regard to:
a) The character of the site and its immediate surroundings, as well as the wider locality, including where applicable the setting of designated heritage assets;

b) The adequacy of the access and the local road network to accommodate the traffic likely to be generated by the proposed development...”

For all the above reasons PP29 is a poor allocation and should be withdrawn from the Plan.

Alternative Sites

When CCC issued its Call for Sites a number of sites were put forward by Copford Parish landowners. Only sites 10226 and 10611 were selected. However, I would encourage the Plan Committee to reconsider sites 10746 and 10765. Together, these sites form the ‘Car Boot Field’ on London Road. In terms of housing numbers these sites could likely deliver in excess of 300 homes. While the sites are classified as good grade agricultural land they have not been farmed for years (the descriptor ‘Car Boot’ is self-explanatory of its current primary use) and the vast majority of the other criteria against which the sites were assessed under the Strategic Land Assessment document come out as either green or amber. Further, many Parish residents would welcome the development of these sites especially when faced with the current allocation and consequent loss of greenfield, farmed land. While CCC’s desire to achieve S.106 funding and amenities through the current PP29 is acknowledged it is not the be all and end all of site allocation. In any event the fact the Car Boot site could absorb 300 homes means the necessary ‘critical mass’ of development would be retained for S.106 purposes.

The allocation of the Car Boot site would also be supported by some of the changes proposed in the recently published amended NPPF. One of the most significant proposed changes is a ‘default yes’ to granting planning permission on sites which are within reasonable distance of a ‘well connected’ rail station. The amended NPPF also provides for a housing density on such sites of between 40 and 50 units per hectare. The total area of the 2 parcels of land forming this Car Boot site is 8.44 hectares meaning 300 homes could be achieved.

In addition to this proposal there are other smaller sites in the Parish which were put forward for allocation. Consideration could be given to site references 10171, 10479, 10531 and 10538. While they are small parcels of land they could be developed in keeping with the aims of the NP to encourage small developments. It would also be in keeping with the proposed revised NPPF which seeks to encourage developments of between 10 and 49 homes.

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

I note that the map does not incorporate the recent development of 50 new homes at Hall Road, so does not show the short distance between developments. Copford has an up-to-date Neighbourhood Plan which prioritises small development designed to meet local needs - there are a number of such sites available. This proposal is hugely out of proportion, it would increase the size of the village by approximately 50% in one go. This would be a greenfield development, against Local Plan priorities. It is far too close to Pits Wood. We can do better to meet stated LP housing priorities.

I object because the traffic in School Road is already very busy and at times it is difficult to get out on to the main road which is also very busy. It would be detrimental to the environment being so close and surrounding the wood , no more peace in the village. Also no bus service in Scool Rd. and no hospital or health centre to cater for people this side of the city. The doctors surgeries are struggling to provide appointments as it is.
There are hardly any green areas of countryside being left to divide the separate villages of Marks Tey, Copford and Stanway. The only benefit to housing would be for small properties for the elderly population, badly needed, which would also free up larger houses for families!

Aside from the fact that with the amount of proposed developments for Colchester the City is going to expand massively, the main area of concern I am addressing here is that in School Road, Copford where there is a proposal for 300 houses being erected on top of the proposal for 1509 homes behind the Marks Tey shops of which 600 would back onto School Road. That is an additional 1809 homes in the immediate area aside from all the other developments already built or in the pipeline. Assuming a minimum of two people in each household would introduce 3,618 additional people into just this part of Colchester alone and if they both drive, the same number of cars. Add a couple of children into the mix and then we are looking at 7,236 additional people.

These new developments are not purely housing local people; they are pulling in people from other areas. This will add to the already overstretched infrastructure issues, the local health services to name one. Trying to get onto the books of a local NHS Dentist is already extremely difficult, if not impossible, as is trying to get an appointment with a GP in a timely manner. The local hospital is already struggling as is the ambulance service. More and more people needing to use these already struggling services will only make matters worse. These services never seem to expand to meet need as is often suggested; they stay the same but just become more and more overstretched. Schools are another concern as the current schools are set up to serve the local villages as they stand. Policing in the area, as it stands, is already inadequate.

There is a concern surrounding other infrastructure such as drainage, water, electricity etc. as these are often impacted adversely by certain weather conditions, especially drainage as the roads regularly flood around here with just a downpour.

Traffic in the area has already increased immensely in the past few years. The other local housing developments, such as in the Tollgate area and the other developments between Copford and Tollgate, have already brought in more cars to just this area alone and that is aside from people visiting the shopping area. The knock on effect, which is already evident, will only get worse. In addition there are health implications of having so many more cars on the road. Public transport is already inadequate.

The building of yet more houses adds to the erosion of green space which has been slowly increasing over the past few years. The Tollgate area has been through and is still going through a massive house building program, which has not only introduced thousands of people into the area along with their cars, but has taken the green space away and is turning the more rural areas into one massive sprawl of houses from Colchester Town outwards.

The use of agricultural land to build properties is increasing and should not be allowed. Such land should be used for its intended purpose, which is to grow food for the population.

The question that has to be asked is why are more and more people being brought into the area when services are struggling to look after the people who are already living here.

Aside from the fact that with the amount of proposed developments for Colchester the City is going to expand massively, the main area of concern I am addressing here is that in School Road, Copford where there is a proposal for 300 houses being erected on top of the proposal for 1509 homes behind the Marks Tey shops of which 600 would back onto School Road. That is an additional 1809 homes in the immediate area aside from all the other developments already built or in the pipeline. Assuming a minimum of two people in each household would introduce 3,618 additional people into just this part of Colchester alone and if they both drive, the same number of cars. Add a couple of children into the mix and then we are looking at 7,236 additional people.

These new developments are not purely housing local people; they are pulling in people from other areas. This will add to the already overstretched infrastructure issues, the local health services to name one. Trying to get onto the books of a local NHS Dentist is already extremely difficult, if not impossible, as is trying to get an appointment with a GP in a timely manner. The local hospital is already struggling as is the ambulance service. More and more people needing to use these already struggling services will only make matters worse. These services never seem to expand to meet need as is often suggested; they stay the same but just become more and more overstretched. Schools are another concern as the current schools are set up to serve the local villages as they stand. Policing in the area, as it stands, is already inadequate.

There is a concern surrounding other infrastructure such as drainage, water, electricity etc. as these are often impacted adversely by certain weather conditions, especially drainage as the roads regularly flood around here with just a downpour.

Traffic in the area has already increased immensely in the past few years. The other local housing developments, such as in the Tollgate area and the other developments between Copford and Tollgate, have already brought in more cars to just this area alone and that is aside from people visiting the shopping area. The knock on effect, which is already evident, will only get worse. In addition there are health implications of having so many more cars on the road. Public transport is already inadequate.

The building of yet more houses adds to the erosion of green space which has been slowly increasing over the past few years. The Tollgate area has been through and is still going through a massive house building program, which has not only introduced thousands of people into the area along with their cars, but has taken the green space away and is turning the more rural areas into one massive sprawl of houses from Colchester Town outwards.

The use of agricultural land to build properties is increasing and should not be allowed. Such land should be used for its intended purpose, which is to grow food for the population.

The question that has to be asked is why are more and more people being brought into the area when services are struggling to look after the people who are already living here.

I wish to object strongly to the proposed site identified in Policy PP29 (Land to the East of School Rd Copford).

The site is not suitable for the proposed development for a multitude of reasons including:

- Local infrastructure is not capable of supporting the additional homes. There is insufficient capacity already at the local schools, GPs and dentists and I do not believe the vital services such as water and sewage would cope.
- The site does not have sufficient access to public transport and the roads are already busy. Trying to join London Rd from School Rd is already a risky activity in rush hour due to traffic volumes. This is even worse as soon as the A12 is blocked and people flow onto smaller roads.
- The development will build over farmland, this is something than can never be replaced and compromises our national food security.
- The quantity of homes on the site is disproportionate to the local area and will create a high density area in a low/medium density village.
- The quantity of proposed homes will causes a significant % increase in the population of the village and will place a strain on local services. It will also change the nature of the Village for existing residents to the detriment.
- It appears that no consideration has been given to the impact it will have on existing residents of the village, especially those whose homes border the site. The quantity of homes suggests that greed and profit is the driving factor behind the plan for the development.

The site is unsuitable for the proposed development and should be removed from the local plan. There must be alternative sites that offer a much better prospect for adding homes to the area.

Regards,

Martin Brand

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

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

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

SEE ATTACHED

see attached

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

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

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

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

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

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

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

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

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

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

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

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

Environmental transformation and climate change

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

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

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

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

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

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

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

Health and Wellbeing

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

Lorry Parking

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

Eight Ash Green and Copford,

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

Marks Tey

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

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

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

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

See Full Submission attachment

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

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

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

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

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