as previous

I am submitting comments on the Regulation 18 draft Local Plan as a resident of Great Horkesley.
The points below reflect observed local conditions relating to infrastructure, transport, accessibility, and settlement sustainability.
They also reference relevant sections of the National Planning Policy Framework (NPPF), so the issues can be evaluated against national planning requirements.
1. Access to Essential Services (NPPF 35, 92, 104, 105)
In Great Horkesley, residents rely on services outside the village for everyday needs.
Although supermarkets such as Asda (3.1 miles) and Tesco (3.2 miles) are geographically close, journeys frequently take 30–40 minutes due to congestion on narrow rural roads.
The only nearer options are a tiny shop in the village, with limited stock, and a small Co-op store with higher prices, which may not be affordable for all households, but that is not within our village.
This results in forced car dependency, which conflicts with NPPF objectives for sustainable, inclusive access to services.
In addition, Great Horkesley has no GP surgery and no pharmacy, meaning residents must travel outside the village for all primary healthcare needs. These journeys are made more difficult by the regular congestion on the surrounding rural road network, which can significantly increase travel times. I personally am often late for appointments, even when taking congestion in to consideration, due to congestion being worse than expected. Leaving 1 hour before an appointment for a distance of 1.5 miles is typical.
This creates further reliance on private vehicles for essential medical access, which is inconsistent with NPPF paragraph 92’s requirement for accessible, inclusive community facilities and the wider NPPF emphasis on reducing car dependency.
2. Walking & Pedestrian Safety (NPPF 92, 100, 104, 110)
Many roads in Great Horkesley have no pavements, and where pavements do exist they are often overgrown, narrowed by vegetation, or poorly maintained, making them difficult or unsafe to use.
These conditions present challenges for children, older residents, and anyone wishing to reach services on foot.
Even for recreational activity such as running, residents often need to drive to neighbouring areas simply to access safe pedestrian routes.
3. Cycling & Active Travel (NPPF 104, 105)
There are no continuous or protected cycle routes within or around the village.
Road widths, traffic speeds, congestion, and visibility issues make cycling difficult and hazardous.
These conditions restrict the ability of residents to make short or safe trips by bicycle, which is contrary to NPPF requirements for promoting active travel and reducing reliance on private vehicles.
4. Road Capacity, Congestion & Strategic Connectivity (NPPF 104, 105, 110, 111)
Great Horkesley’s road network consists largely of narrow, rural lanes not designed for high volumes of traffic.
Congestion is common at peak times and affects even short local journeys.
Although the A12 passes very close to the village, there is no direct junction, meaning all traffic must travel via already congested minor roads to reach strategic routes.
It can take 30 minutes or more to reach the A12 solely because of access constraints.
Under NPPF paragraph 111, development should not proceed where cumulative traffic impacts are severe, or where safe and suitable access is not available.
5. Settlement Character & Rural Context (NPPF 124, 174)
Great Horkesley retains a rural character with limited services, narrow road infrastructure, and landscape-sensitive edges.
Any significant increase in development would need to demonstrate respect for this context and show how it avoids harming local identity, landscape setting, or the function of the settlement.
6. Infrastructure Planning Requirements (NPPF 20 & 35)
NPPF paragraph 20 requires Local Plans to set out infrastructure needs, delivery mechanisms, timing, and funding.
To allow proper assessment of proposed growth in Great Horkesley, the following information would typically be needed:
Highways and junction capacity modelling
Transport sustainability assessments
Pedestrian and cycling safety evaluations
Costed Infrastructure Delivery Plan
Utilities, drainage, and sewerage capacity studies
Access-to-services analysis
Assessment of cumulative traffic impacts
Consideration of strategic connectivity to the A12
Without this information being publicly available, it is difficult to evaluate whether proposed growth is justified, deliverable, or consistent with national policy, as required by NPPF paragraph 35.
7. Summary
These comments are provided to assist in evaluating whether additional development in Great Horkesley would meet national planning requirements relating to:
safe access
sustainable transport
infrastructure capacity
settlement character
evidence-based decision-making

The site includes the Grade II listed Woodhouse Farmhouse (LEN 1222684), and is situated potentially within the setting of the Small multivallate hillfort known as Pitchbury Ramparts Scheduled Monument (LEN 1019959).

Initial assessment

While development could be acceptable, a proforma Heritage Impact Assessment will help to confirm the site’s suitability from a historic environment perspective and to identify appropriate mitigation measures or opportunities for enhancement. The resulting recommendations should then be incorporated into criteria ‘l’ of the policy.

By creating a new connecting path through the proposed development site, Footpaths 36, 37 and 38 can be brought together into a single, continuous multi‑user route. This is a genuine opportunity to deliver a shared corridor designed for walkers, cyclists and equestrians, rather than a footpath network that serves only one group. Linking the paths in this way would maintain and enhance access to the surrounding countryside, protect the rural character of the area, and provide a safe, attractive and inclusive route for everyday movement and recreation. This multi‑user connection is the key public benefit of the proposal.

I’m concerned by the scale of the allocation and the way 150 of 400 homes have already been approved outside the Local Plan process.

The proposed contributions towards offsite infrastructure total only £15k per dwelling, far short of the £40k required according to the infrastructure audit. CCC should insist that speculative applicants pay their full share of infrastructure costs.

I’m also concerned that sewage capacity will prevent the homes ever being built. Anglian Water has recommended refusal because the West Bergholt STW is at capacity and there are no plans for improvements until after 2030.

We support this allocation as a logical site, with part of the site already having outline planning permission under application number 250545. The additional adjacent site is a logical extension and could provide additional access for the 400 homes, away from the School and busy, narrow part of Coach Road.
The access approved by Highways was cited by the majority against the planning application, additional vehicular access offers some relief from this concern, plus it offers additional access in case of emergencies or emergency works, as, for example, we believe a water main runs under the proposed entry road.

Great Horkesley is classed as medium sized in the settlement hierarchy. Great Horkesley is essentially linear in shape and has developed over time along the old Roman road that radiates away from north Colchester (now the A134). More recently development has spread westwards along a number of roads off the main road. Land to the east of the main road has remained relatively free of development and is more open in character. Great Horkesley is fragmented with the main core of the settlement to the south and two smaller fragments to the north along the A134. The southern edge of the main part of the village is approximately 0.6km from the Colchester urban edge and is located north of the A12. There are a range of services and facilities within the village.

An allocation of 400 new dwellings is being proposed on land to the north of Coach Road. The boundary of the Dedham Vale National Landscape lies approximately 2km to the north of the site proposed for allocation. Given the relative proximity to the National Landscape, it is considered that the addition of approximately 400 more dwellings as proposed through policy PP34 has the potential to indirectly impact and reduce tranquillity levels in the National Landscape linked to the inevitable increase in traffic levels and traffic noise on the rural road network of the Dedham Vale National Landscape and from increased visitor pressure for recreational activities.

Paragraph 189 of the National Planning NPPF states that: "Great weight should be given to conserving and enhancing landscape and scenic beauty in National Landscapes" and that "development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas".

Draft Local Plan Policy LC2 states that ’Development will only be supported within or on land within the setting of the Dedham Vale National Landscape that: (b) Does not adversely affect the tranquillity and the National Landscapes good quality night/dark skies, taking account of guidance in The Dedham Vale National Landscape Lighting Design Guide.’ The policy continues that ‘Applications for major development or near the boundary of the Dedham Vale National Landscape will be refused unless in exceptional circumstances.’

The exceptional circumstances have not been evidenced, and tranquillity levels will be impacted.

Paragraph 198 of the National Landscape states that ‘Planning policies should ensure that new development is appropriate for its location taking into account the likely effects of pollution on... the natural environment" and to "b) identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason" and ‘c) limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation’.

It is not clear from the Sustainability Assessment how or if impacts on the National Landscape have been considered. The scale of development being proposed at Great Horkesley, could have a significant negative impact within the setting of the Dedham Vale National Landscape.

Across the settlements of Boxted, Dedham Heath, Langham, and Great Horkesley a total of 1,488 new dwellings are being proposed. All of these settlements lie in the setting to the Dedham Vale National Landscape. Alone and cumulatively the potential for increased light pollution along the southern boundary to the National Landscape from these developments is very high.

The National Landscape team considers that lighting impacts should have been more thoroughly considered before promoting the allocation of site PP34 to better understand effects on the tranquillity/Dark Skies. Completing such assessments would also demonstrate that the City Council has actively sought to meet its Duty under Section 85 of the Countryside and Rights of Way Act 200.

For these reasons it is considered that there is a policy conflict between paragraphs 189, and 198 of the National Planning Policy Framework and the objectives of emerging Local Plan Policies LC2 and PP34.

Policy ST4 states that ‘The Council will consider the requirement for new development within the countryside to meet identified development needs in accordance with Colchester's spatial strategy while supporting the vitality of rural communities. This will be balanced against ensuring development does not have an adverse impact on the different roles and relationships between settlements and their separate identities, valued landscapes, the intrinsic character and beauty of the countryside and visual amenity. The intrinsic character and beauty of the countryside will be recognised and assessed, and development will only be permitted where it would not adversely affect the intrinsic character and beauty of the countryside.

Development on this site at this scale could have a significant adverse impact on local landscape character and extend development westwards in Great Horkesley into the open countryside. It is considered that there is a conflict between policies ST4, LC1 and Policy PP34.

In terms of infrastructure Policy ST7 is relevant. Policy ST7 states that ‘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.

The Colchester Infrastructure Audit and Delivery Plan Stage 3 Report (IADP) produced in October 2025 for Colchester City Council concluded that the West Bergholt WRC which serves Great Horkesley concluded that West Bergholt WRC has limited or no baseline capacity with no improvement plan identified in AW’s AMP8 Business Plan for delivery before 2030. Early phasing of growth in this drainage catchments may be restricted until improvement plans are developed for 2030 onwards (AMP9 or AMP10)

The lack of baseline capacity at the West Bergholt WRC to manage waste water from the proposed growth in Great Horkesley coupled with the lack of planned upgrades to the WRC and the lack of secured funding for any works needed at the Langham WRC raises questions around the ability to deliver this site within the plan period. If this site is retained in the Submission Local Plan more evidence is needed to demonstrate that the WRC and surface water management issues can be resolved in a timely manner to protect areas beyond the site, and r to resolve potential conflicts with the objectives of policy ST7

Bloor Homes are the promoter of part of the proposed site allocation at Land north of Coach Road, Great Horkesley, as identified on the Proposals Map associated with the Preferred Options Local Plan (POLP).

Bloor Homes are the promoter of the southern field of the two which are covered by the site allocation area. This land has a Strategic Land Availability Assessment (SLAA) reference of ID: 10691. Bloor Homes submitted an outline planning application for up to 150 dwellings and a community car park (Ref: 250545) in March 2025. Following a positive Officer recommendation, the planning application achieved a resolution to grant planning permission at the 27 November 2025 Planning Committee. The planning application process has determined that the site is a suitable location for residential development.

As set out in Bloor Homes’ representations to draft Policy ST5 and ST5.2 there is a clear need for additional site allocations to be made to ensure that the new Local Plan is capable of meeting the minimum Standard Method housing need. At present, the strategic approach to building a robust supply is not justified and is inflexible. The proposed supply would not be capable of responding to changes in the housing market during the Plan period. Furthermore, the supply of proposed site allocations contains several sites where capacity (no. of dwellings) has been overestimated, this includes the draft allocation Land north of Coach Road, Great Horkesley (Policy PP34).

Moving forward towards the Pre-Submission stage it appears inevitable that, alongside reviewing the above matters, the Council will need to make additional site allocations for residential development. In making new site allocations the Council will need to follow their chosen Spatial Strategy to deliver growth and have due regard for the proposed Settlement Hierarchy which ranks existing settlements based on their sustainability credentials. As set out in Bloor Homes’ representations to draft Policy ST3, Great Horkesley is a sustainable settlement capable of accommodating housing growth.

Given the evident need for the Council to identify additional land for housing development as part of the Pre-Submission Local Plan, Bloor Homes are promoting additional land to the south of Old House Road, Great Horkesley. The site covers 23.25ha and extends south from Old House Road. The site area includes the land which is subject to a resolution to grant planning permission (Reference: 250545) for 150 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site. Bloor Homes have instructed work to Masterplan this wider opportunity.

A Framework Masterplan covering the entirety of the land promoted by Bloor Homes (including the area covered by application 250545) has been submitted in support of these representations. The Framework Masterplan provides an indicative layout and demonstrates that a site capacity of 400 dwellings is achievable (based on 35 dwellings per hectare). This is the same density accepted by the Council in the determination and assessment of planning application 250545.

The Framework Masterplan delivers the following:

• 400 dwellings across a developable area of 11.25ha. The indicative layout for the area of the site covered by the current draft site allocation replicates that shown on the Framework Masterplan for the planning application 250545.

• An area of community opportunity land in the locality of the existing village hall. This land has been set aside to support the delivery of new community infrastructure should it be required. Bloor Homes are happy to discuss this opportunity with the Council and local stakeholders. Bloor Homes are currently open minded as to the use of this opportunity land and have in their view a positive working relationship with the Parish Council.

• The access strategy provides two points of access, one via Coach Road (as per the proposals agreed by ECC in the determination of planning application 250545) and the other via Old House Road. As set out in the provided Highways Technical Note the proposed access strategy has been subject to pre-application advice with Essex County Council. In addition, the site will integrate successfully with the existing local highway network and existing walking routes. This includes providing a direct link to the existing village hall and its associated facilities. The delivery of an access off Old House Road, will reduce traffic flows on Coach Road by acting as a more direct route for people heading north towards The Causeway and other local routes.

• The Masterplan is landscape led, with the developable area sited in accordance with the findings of the local landscape and heritage assessments.

• Over 7ha of public open space. This is well in excess of the current local policy requirements which requires 10% of the site area to be public open space.

• The public open space provides equipped play space and new walking routes which integrate successfully within existing routes. The existing Public Right of Way (ProW) running through the site will be retained in its current location.

• The retention of existing vegetation and trees provides extensive opportunities to deliver new planning and landscaping.
The aim being to secure on site biodiversity enhancements.

• Set within the public open space is a network of sustainable urban drainage features to ensure that the proposed development does not increase flood risk on site or off-site. These drainage features can be designed to have an amenity and or ecological value.

The land being promoted by Bloor is suitable, achievable and available for development. This is evidenced by the Council’s decision-making in relation to the outline planning application which covers the Land to the north of Coach Road and the further technical and masterplanning work provided in support of these representations.

The site can help the Council deliver a robust housing supply to meet its Standard Method need. The site should be subject to a new SLAA appraisal and Sustainability Appraisal. These appraisals should then be published as part of or prior to the Pre-Submission Local Plan consultation. There is a robust and clear case for the entirety of the site to be allocated for residential development. To demonstrate the robustness of the Masterplan and the overall suitability and deliverability of the site these representations are also supported by a Vision Document and Technical Notes in relation to: Highways, Flood Risk & Drainage, Landscape, Ecology and Heritage.

Bloor Homes will continue to progress their design and technical work and will look to deliver the entire site as soon as practically possible. Bloor Homes will also continue to proactively engage with Great Horkesley Parish Council and would welcome further engagement with the City Council regarding the wider site opportunity and its potential to assist in meeting local housing needs. A formal request for the planning pre-application advice will be submitted to the City Council in early 2026.

In terms of the draft policy wording relating to the existing draft allocation area at Land north of Coach Road, Great Horkesley, Bloor Homes make the following comments:

• The policy does not currently reference the community car park which will be secured via the pending approval of planning application 250545. The delivery of the car park should be written into the policy. The car park, which will assist in alleviating local pressures at peak school drop off/pick up times, impacts upon the developable area available for residential development. This is not currently accounted for in the draft Policy or the Council’s capacity calculations.

• Bloor Homes currently object to development requirements h) and i). In proactively and positively planning for growth the Council have a responsibility to work with their infrastructure partners to ensure growth is deliverable and that there is sufficient capacity at local infrastructure. This work will ensure solutions are in place to support development coming forward at the planning application and implementation stages. Bloor Homes acknowledge the local foul and surface water capacity constraints identified by the POLP and its evidence base. However, it is clear that the Council and Anglian Water have more work to do to plan for growth and agree solutions to existing capacity problems. These solutions should be confirmed by an updated Infrastructure Audit and Delivery Plan at the Pre-Submission stage of the Local Plan process. The current approach of identifying capacity problems with in some cases no firm or costed solution will not support the delivery of growth and thus will jeopardise the Council’s ability to deliver the minimum housing requirement. The Council have a responsibility to work with Anglian Water on these issues as part of preparing the Local Plan.

• The use of a Grampian Condition limiting the occupancy, as per the Council’s current Development Management approach, is not an appropriate or robust strategy to support the delivery of new homes.

Bloor Homes trust that these comments will be taken into account as the Local Plan preparation reaches the Pre-Submission stage in 2026. Bloor Homes also wish to confirm to the Council, that regardless off the emerging proposals for additional development outside of the current draft allocation boundary, that they are committed to delivering up to 150 dwellings on the land which is subject to a resolution to grant planning permission and falls within the current allocation boundary.

Mr & Mrs Knighton own 6.67 hectares (ha) of agricultural land to the northeast of Coach Road, Great Horkesley, as set out on the accompanying Site Location Plan (drawing no. X21482-01b), which benefits from an existing access onto Coach Road. This land immediately abuts the approved Bloor Homes development for 150 homes (application ref. 250545) to the southeast and forms part of the wider draft allocation for approximately 400 homes on the western edge of Great Horkesley village, as set out in Policy PP34 of the Local Plan document.

Notably Appendix E of the CCC’s Sustainability Appraisal (February 2025) concludes that: “The development of this site [i.e. the Bloor site] and the adjacent site [i.e. Mr & Mrs Knighton’s land] would form a logical extension to Great Horkesley when compared against alternatives. The site is well connected to services and facilities within the village.”

Furthermore, paragraph 2.98 of the Sustainability Appraisal confirms that Great Horkesley is just 0.6 km from the urban edge of Colchester and that there are a range of services and facilities within the Village. These include but are not limited to a nursery and primary school, village hall, village green and children’s play equipment, church, post office and convenience store, public house and petrol station. Great Horkesley has good public transport links for a semi-rural settlement and is served by existing bus routes on Coach Road and Nayland Road that link the village to Bury St Edmunds, Sudbury and Colchester, including Colchester railway station. In summary the Village is a sustainable location for proportionate future growth.

The accompanying Masterplan (drawing no. 792-FGA-ZZ-XX-D-A-1010) demonstrates how a residential-led development could be accommodated in this location while respecting the layout, form and scale of the existing village and adjoining Bloor development, and while minimising impacts on the character and appearance of the wider countryside beyond.

The layout is structured around maximising exposure to green corridors, with development parcels that predominantly face outwards and overlook areas of new public open space, existing greenspace or new tree-lined streets, which are a primary urban design consideration in contemporary landscape-led schemes. Greenspace from the recently approved Bloor development to the south will be continued northwards into the centre of this site, thereby providing a variety of amenity, biodiversity and surface water drainage benefits in a central park and creating an attractive place to live.

New pedestrian and cycle routes leading through the structured green spaces will provide excellent connectivity from within the site, through the adjacent Bloor development and on towards the existing nursery, primary school and other facilities in the village.

It is noted that CCC and Essex County Council (ECC) currently prefer this site to be accessed exclusively through the Bloor development. Although that may be feasible, subject to detailed discussions with Bloor, there are also good reasons to plan for a vehicular access directly from Coach Road to the southwest by either retaining and making use of the existing access at the site’s southern-most corner or by relocating this access midway along the site’s frontage with Coach Road. Ensuring that Mr & Mrs Knighton’s land retains its own independent access will provide the following benefits:

(i) Enable the site to come forward sooner and therefore support the delivery of new homes in the all-important first five years of the plan period. Whereas if CCC and ECC insist that vehicular access must be derived from the Bloor site, development on Mr & Mrs Knighton’s land could be delayed by several years until Bloor have built and handed over an adoptable highway to ECC.
(ii) Lead to better living conditions and residential amenity for new residents on the Bloor site, who would otherwise have vehicles from up to 200 additional dwellings passing their homes each day.
(iii) Help to promote sustainable modes of travel from Mr & Mrs Knighton’s land, by providing a more direct foot and cycle path through the Bloor development to the village amenities to the east and a longer vehicular route to the southwest via Coach Road.
(iv) Better access and contingency for emergency services, with scope for a main access from Coach Road and a secondary or emergency-only access through the Bloor development. This will be safer than the whole allocation being served solely from one point of access on the Bloor development.
(v) Delivery of an access that addresses the majority of objections to the Bloor planning application, which were concerned with the close proximity of the Bloor access and the entrance to the primary school. A separate access to the southwest of Mr & Mrs Knighton’s land offers an opportunity to reduce the volume of vehicle movements near the school, particularly for those travelling from the allocation towards West Bergholt (via Nayland Road) or towards Sudbury (via Old House Road).

Intermodal Transportation advise that a standard priority junction can be provided onto Coach Road in accordance with relevant Highway Guidance and with adequate visibility splays in both directions. In summary the accompanying Masterplan (drawing no. 792-FGA-ZZ-XX-D-A-1010) provides the flexibility to access Mr & Mrs Knighton’s land through the Bloor site and / or from an independent access direct from Coach Road. The latter could involve retaining and making use of the existing access at the site’s southern-most corner or relocating this access midway along the site’s frontage with Coach Road.

A single main vehicular loop within the site will support an efficient use of land and distribution of block and plot frontages, with development focussed around seven double-fronted residential parcels which face predominantly to the northwest and southeast and two single-fronted residential parcels which face to the southeast. All of these parcels are roughly rectangular in shape.

Existing trees and hedgerows comprise the site's key green assets, in terms of habitats and biodiversity, and will be retained and reinforced with new planting wherever possible.

Approximately 5.79 ha of Mr & Mrs Knighton’s land is identified for built form including in the region of 170 to 200 new dwellings (with 30% affordable homes) at a net residential density of approximately 30 to 35 dwellings per ha (dph), new streets and an equipped play area for children.

The landowners envisage that the new homes will be built to the latest design and sustainability standards, including but not limited to net zero carbon (in accordance with Policies NZ1 and NZ2), achieving greater water efficiencies of at most 80 litres per person per day (Policy NZ3), a mix of market, affordable home ownership, affordable rent and older people housing (in accordance with Policy H1) and 2% self and custom build housing (Policy H6).

The remaining 0.88 ha of the site will be dedicated to public open and greenspace, SuDS to attenuate surface water on-site and areas to achieve a minimum 10% net gain in biodiversity, as required by the Environment Act.

Section 3.3.11 of the Colchester Water Cycle Study (February 2025) acknowledges that Great Horkesley is served by the West Bergholt Water Recycling Centre (WRC), which is at capacity and has limited scope to serve additional allocations when combined with existing commitments. However, the report also recommends that an 80 litre per person per day (l/p/d) per capita consumption (PCC) limit be imposed for the allocated sites in this catchment to facilitate the delivery of sites early in the plan period and that developers demonstrate they have agreed available capacity at the WRC and associated sewer network with Anglian Water Services prior to submitting planning applications. Development at this site will be designed to comply with these recommendations and the necessary demonstration of capacity will be provided prior to a planning application being made.

In summary Mr & Mrs Knighton’s land is available, achievable and suitable for a proportionate extension to the village and can deliver benefits for the local community such as: (i) new market, affordable and self / custom build homes to meet identified needs; (ii) new public open space and an equipped play area; and, (iii) enhanced pedestrian and cycle access between the existing village, the adjacent Bloor development and the site.

New residential-led development in this location could also provide planning contributions to enhance capacity at the local primary and secondary schools, health centre, village hall and / or other local community facilities.

Therefore Mr & Mrs Knighton support the allocation of this land, and the adjoining Bloor development, for approximately 400 homes in Policy PP34 of the Local Plan document. Mr & Mrs Knighton also welcome the opportunity to prepare a collaborative and comprehensive masterplan for the entire site allocation, working alongside the Council, Bloor Homes and local stakeholders.

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

Bloor Homes are the promoter of part of the proposed site allocation at Land north of Coach Road, Great Horkesley, as identified on the Proposals Map associated with the Preferred Options Local Plan (POLP).

Bloor Homes are the promoter of the southern field of the two which are covered by the site allocation area. This land has a Strategic Land Availability Assessment (SLAA) reference of ID: 10691. Bloor Homes submitted an outline planning application for up to 150 dwellings and a community car park (Ref: 250545) in March 2025. Following a positive Officer recommendation, the planning application achieved a resolution to grant planning permission at the 27 November 2025 Planning Committee. The planning application process has determined that the site is a suitable location for residential development.

As set out in Bloor Homes’ representations to draft Policy ST5 and ST5.2 there is a clear need for additional site allocations to be made to ensure that the new Local Plan is capable of meeting the minimum Standard Method housing need. At present, the strategic approach to building a robust supply is not justified and is inflexible. The proposed supply would not be capable of responding to changes in the housing market during the Plan period. Furthermore, the supply of proposed site allocations contains several sites where capacity (no. of dwellings) has been overestimated, this includes the draft allocation Land north of Coach Road, Great Horkesley (Policy PP34).

Moving forward towards the Pre-Submission stage it appears inevitable that, alongside reviewing the above matters, the Council will need to make additional site allocations for residential development. In making new site allocations the Council will need to follow their chosen Spatial Strategy to deliver growth and have due regard for the proposed Settlement Hierarchy which ranks existing settlements based on their sustainability credentials. As set out in Bloor Homes’ representations to draft Policy ST3, Great Horkesley is a sustainable settlement capable of accommodating housing growth.

Given the evident need for the Council to identify additional land for housing development as part of the Pre-Submission Local Plan, Bloor Homes are promoting additional land to the south of Old House Road, Great Horkesley. The site covers 23.25ha and extends south from Old House Road. The site area includes the land which is subject to a resolution to grant planning permission (Reference: 250545) for 150 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site. Bloor Homes have instructed work to Masterplan this wider opportunity.

A Framework Masterplan covering the entirety of the land promoted by Bloor Homes (including the area covered by application 250545) has been submitted in support of these representations. The Framework Masterplan provides an indicative layout and demonstrates that a site capacity of 400 dwellings is achievable (based on 35 dwellings per hectare). This is the same density accepted by the Council in the determination and assessment of planning application 250545.

The Framework Masterplan delivers the following:

• 400 dwellings across a developable area of 11.25ha. The indicative layout for the area of the site covered by the current draft site allocation replicates that shown on the Framework Masterplan for the planning application 250545.

• An area of community opportunity land in the locality of the existing village hall. This land has been set aside to support the delivery of new community infrastructure should it be required. Bloor Homes are happy to discuss this opportunity with the Council and local stakeholders. Bloor Homes are currently open minded as to the use of this opportunity land and have in their view a positive working relationship with the Parish Council.

• The access strategy provides two points of access, one via Coach Road (as per the proposals agreed by ECC in the determination of planning application 250545) and the other via Old House Road. As set out in the provided Highways Technical Note the proposed access strategy has been subject to pre-application advice with Essex County Council. In addition, the site will integrate successfully with the existing local highway network and existing walking routes. This includes providing a direct link to the existing village hall and its associated facilities. The delivery of an access off Old House Road, will reduce traffic flows on Coach Road by acting as a more direct route for people heading north towards The Causeway and other local routes.

• The Masterplan is landscape led, with the developable area sited in accordance with the findings of the local landscape and heritage assessments.

• Over 7ha of public open space. This is well in excess of the current local policy requirements which requires 10% of the site area to be public open space.

• The public open space provides equipped play space and new walking routes which integrate successfully within existing routes. The existing Public Right of Way (ProW) running through the site will be retained in its current location.

• The retention of existing vegetation and trees provides extensive opportunities to deliver new planning and landscaping.
The aim being to secure on site biodiversity enhancements.

• Set within the public open space is a network of sustainable urban drainage features to ensure that the proposed development does not increase flood risk on site or off-site. These drainage features can be designed to have an amenity and or ecological value.

The land being promoted by Bloor is suitable, achievable and available for development. This is evidenced by the Council’s decision-making in relation to the outline planning application which covers the Land to the north of Coach Road and the further technical and masterplanning work provided in support of these representations.

The site can help the Council deliver a robust housing supply to meet its Standard Method need. The site should be subject to a new SLAA appraisal and Sustainability Appraisal. These appraisals should then be published as part of or prior to the Pre-Submission Local Plan consultation. There is a robust and clear case for the entirety of the site to be allocated for residential development. To demonstrate the robustness of the Masterplan and the overall suitability and deliverability of the site these representations are also supported by a Vision Document and Technical Notes in relation to: Highways, Flood Risk & Drainage, Landscape, Ecology and Heritage.

Bloor Homes will continue to progress their design and technical work and will look to deliver the entire site as soon as practically possible. Bloor Homes will also continue to proactively engage with Great Horkesley Parish Council and would welcome further engagement with the City Council regarding the wider site opportunity and its potential to assist in meeting local housing needs. A formal request for the planning pre-application advice will be submitted to the City Council in early 2026.

In terms of the draft policy wording relating to the existing draft allocation area at Land north of Coach Road, Great Horkesley, Bloor Homes make the following comments:

• The policy does not currently reference the community car park which will be secured via the pending approval of planning application 250545. The delivery of the car park should be written into the policy. The car park, which will assist in alleviating local pressures at peak school drop off/pick up times, impacts upon the developable area available for residential development. This is not currently accounted for in the draft Policy or the Council’s capacity calculations.

• Bloor Homes currently object to development requirements h) and i). In proactively and positively planning for growth the Council have a responsibility to work with their infrastructure partners to ensure growth is deliverable and that there is sufficient capacity at local infrastructure. This work will ensure solutions are in place to support development coming forward at the planning application and implementation stages. Bloor Homes acknowledge the local foul and surface water capacity constraints identified by the POLP and its evidence base. However, it is clear that the Council and Anglian Water have more work to do to plan for growth and agree solutions to existing capacity problems. These solutions should be confirmed by an updated Infrastructure Audit and Delivery Plan at the Pre-Submission stage of the Local Plan process. The current approach of identifying capacity problems with in some cases no firm or costed solution will not support the delivery of growth and thus will jeopardise the Council’s ability to deliver the minimum housing requirement. The Council have a responsibility to work with Anglian Water on these issues as part of preparing the Local Plan.

• The use of a Grampian Condition limiting the occupancy, as per the Council’s current Development Management approach, is not an appropriate or robust strategy to support the delivery of new homes.

Bloor Homes trust that these comments will be taken into account as the Local Plan preparation reaches the Pre-Submission stage in 2026. Bloor Homes also wish to confirm to the Council, that regardless off the emerging proposals for additional development outside of the current draft allocation boundary, that they are committed to delivering up to 150 dwellings on the land which is subject to a resolution to grant planning permission and falls within the current allocation boundary

are writing on behalf of our client, the Defence Infrastructure Organisation (DIO), which is part of the
Ministry of Defence and is responsible for managing the military estate, including the provision of homes
for service personnel across the UK.
We submit representations to the Colchester Regulation 18 Local Plan Consultation covering multiple
DIO-owned sites and strategic concerns regarding the emerging Local Plan. These representations
have been prepared to assist Colchester City Council in developing an effective and deliverable plan
that recognises both local priorities and national defence requirements.
In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and
development plans recognise that MOD Establishments are of strategic military importance to the UK.  It
is important that planning authorities consult with the MOD during the preparation of their plans and take
into account the need to safeguard operational sites.
To support the ongoing military training and operations within the City it is considered that the inclusion
of a specific policy in the Local Plan to recognise these requirements would be beneficial and accord
with national planning policy.
Paragraph 102 of the National Planning Policy Framework (December 2024) states that ‘planning
policies and decisions should promote public safety and take into account wider security and defence
requirements including by ‘b) recognising and supporting development required for operational defence
and security purposes, and ensuring that operational sites are not affected adversely by the impact of
other development proposed in the area.’
Summary of Other Representations
Land South of Birch Brook
Our client is concerned with the proposed designation of this defence land as a Strategic Biodiversity
Area under Policy ST2. We object to this blanket designation which could prevent continued
operational use and future land release requirements, thereby conflicting with national defence
objectives as recognised in NPPF Paragraph 102b.
We also raise significant concerns regarding the spatial strategy's over-reliance on large, complex
strategic allocations in village locations, which introduces substantial delivery risks. We estimate that
approximately 2,970-3,695 dwellings from major strategic allocations are at medium to very high risk
of non-delivery within the Local Plan period. The Plan requires greater flexibility, contingency planning,
and a more diverse range of site sizes and locations to maintain housing supply resilience as supported
by the NPPF.
Middlewick Ranges
Whilst we acknowledge the proposed de-allocation of this 120-hectare site as a housing allocation,
our client objects to the dual designation as both Local Green Space under Policy GN3 and Strategic
Biodiversity Area under Policy ST2. This approach creates unnecessary policy duplication and
potential conflicts that could harm proper ecological management and enhancement.
The Local Green Space designation is also inappropriate for extensive tracts of land where the primary
value lies in biodiversity function rather than recreational or community use, contrary to National
Planning Policy Framework (NPPF) Paragraphs 106-108. We request removal of the Local Green
Space designation to avoid policy confusion and constraints on effective habitat management as
required by the NPPF.
DIO Berechurch
This 3.6 hectare site is being considered for operational defence use, potentially including Service
Family Accommodation (SFA) development to address urgent identified needs. We object to its
proposed inclusion within a Strategic Biodiversity Area designation, which lacks robust evidential
justification and fails to recognise the site's operational importance in accordance with NPPF
Paragraph 102b.
We also highlight that there is an established operational requirement for the site for military purposes,
this includes the need deliver new Service Family Accommodation (SFA) to meet a significant shortfall
in provision in Colchester, yet the Local Plan provides no recognition or policy support for this
requirement contrary to national defence priorities set out in NPPF Paragraph 102b.
The site also contains existing electrical infrastructure and is surrounded by development on three
sides, questioning its suitability as a biodiversity area. We emphasise the need for operational flexibility
to adapt to changing defence requirements without undue policy constraints. We recommend inclusion
of a specific Military Establishments policy to support development that enhances operational
capability and recognise SFA provision as essential workers housing.
Open Space Designations Merville Barracks
Our client objects to the proposed designation of two parcels within our clients’ estates (at Drury
Meadows and Montgomery Estate) as Open Space under Policy GN6. These sites, totalling
approximately 2.17 hectares, are suitable for SFA infill development and do not provide demonstrable
public recreational or amenity value, nor is there funding identified within the Local Plan evidence base
for the long term management and maintenance of this land as open space. The designations lack
robust justification as the sites were not assessed within the Council's Open Space Report (2023),
rendering the approach unsound.
We highlight that there is an urgent need in Colchester to deliver new SFA, yet the Local Plan provides
no recognition or policy support for this requirement contrary to national defence priorities set out in
NPPF Paragraph 102b. We also recommend inclusion of a specific Military Establishments policy to
support development that enhances operational capability and recognise SFA provision as essential
workers housing.
Key Requested Revisions
We respectfully request the following amendments to strengthen the Plan's deliverability and
soundness:
1. Remove Strategic Biodiversity designations from operational defence land (Land South
of Birch Brook and DIO Berechurch).
2. Remove Local Green Space designation from Middlewick Ranges to avoid policy
duplication and given it is an extensive tract of land and therefore unsuitable.
3. Remove Open Space designations from SFA estate land or provide policy flexibility for
SFA development.
4. Include specific policy recognition and support for general defence requirements and
Service Family Accommodation provision.
5. Incorporate greater flexibility and contingency planning within the spatial strategy.
6. Diversify housing supply through a broader range of site sizes and locations.
7. Establish clear triggers for releasing reserve sites to maintain housing supply
resilience.
Conclusion
The DIO remains committed to working collaboratively with Colchester City Council to ensure the
emerging Local Plan provides an appropriate and flexible framework that recognises both local
housing needs and national defence priorities. Our representations seek to strengthen the Plan's
effectiveness, deliverability, and resilience whilst ensuring that essential defence operations can
continue without unnecessary policy constraints.
We believe that addressing these concerns will result in a more robust and sounder Local Plan that
better serves the needs of Colchester's communities whilst fulfilling the Council's obligations to support
national defence requirements.
We look forward to your consideration of these matters and to continued engagement throughout the
Local Plan process.

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.

This submission from Great Horkesley Parish Council (GHPC) responds to the proposition (PP34)
contained in the Preferred Option Local Plan consultation that before 2041 around 400 dwellings
should be provided on two adjacent sites north of Coach Road in the village.
2. The matter is complicated because the City Council has already given outline consent, albeit
conditionally, for the development of 150 homes on the more southerly site, opposite ribbon
development on the south side of Coach Road. To forestall local criticism, it is restated here that
GHPC objected to that consent. That said, for the purposes of this submission, it is accepted that
this consent has effectively determined the status of this southerly site as housing land and it will
not be contested here.
The existing Great Horkesley settlement
3. The preamble contains a significant error in the sentence “…development has spread westwards
along a number of roads off the main road. Land to the east of the main road has remained relatively
free of development and is more open in character.” At the time of writing, a reserved matters
application for consent for 100 dwellings to be built to the east of the main road around Great
Horkesley Manor is close to agreement. Also to the east of the main road, in the late 1980s 60
dwellings were built south of The Crescent, triggering sporadic infill, still ongoing, in the years
since.
4. In the same period, on the west side of the main road, in the mid-1990s 34 houses were built at
the end of Keelers Way, whilst in the following decade, 154 dwellings were built on Tile House Farm.
Thus as far as east and west are concerned, the honours are more or less even: two significant sites
on each side, with dwelling numbers roughly of the same magnitude. Whilst it is true that the 100
houses around The Manor have yet to be built, it is disingenuous to describe that land as free of
development and … more open in character when it is most unlikely to be so by the time the
emerging Local Plan is adopted.
5. This is not cavilling over minor detail. The land around The Manor appears in the current Local
Plan precisely because it has well-defined boundaries, in contrast to sites west of the current
settlement boundaries which were offered under the previous Call for Sites, adoption of which as
housing land was recognised as likely to lead to a sprawl out into the open countryside. This
potential sprawl was identified best avoided in the draft Settlement Boundary Review prepared by
the planning authority as part of the current plan review process and sent to GHPC for comment.
GHPC updated the draft, mostly identifying changes in local facilities, and returned it to the
planning authority.
6. No explanation has ever been given for the decision to perform a volte face and recommend for
major development land which had previously been identified by both authorities as open
countryside best left undeveloped. At the very least, one would have expected draft PP34 to have
recognised the problematic absence of strong natural boundaries between Coach Road and Old
House Road, just as did the Settlement Boundary Review, but it is silent on the matter.
The development proposal in PP34
7. GHPC would argue that, taking into account the 150-dwelling site that has outline consent, there
are obvious boundaries to the existing and consented development north of Coach Road. In the
east, there is frontage onto Nayland Road and The Causeway, the main road. To the south, the
boundary is Coach Road itself, closely developed at the eastern end but less so towards
Woodhouse Corner, on the settlement boundary. From the main road to Woodhouse Corner, the
developed land forms (or strictly will form) a rough quadrilateral with the Jubilee Green at its
centre.
8. At its western end, the northern edge of this quadrilateral of development is the only strong
boundary between Coach Road and Old House Road. It should be recognised as such and
respected. To go beyond it, as draft PP34 proposes, is to invite, in decades to come, loss of
countryside to urban sprawl, as foreseen in the agreed Settlement Boundary Review. To avoid
this, there should as a matter of policy be no development north of the site which currently has
outline consent.
9. Furthermore, because the more northerly site of those identified in PP34 is bounded on three
sides by open countryside, albeit with the rural part of Coach Road running through it,
development here will be particularly intrusive, especially when viewed from Old House Road to
the north, the village green to the north east and the public right of way which connects them.
Housing numbers
10. Failing to take account of the 100 dwellings to be built around The Manor enables the impact
of the 400 proposed for the PP34 site to be set in a false context. In recent decades Great
Horkesley has not been shy of major development: Tile House Farm was notably the largest greenfield site in the relevant plan period and was built with full support from GHPC. The Parish Council
also supported the inclusion of the land around the Manor in the current Local Plan and has worked
with other stakeholders to ensure that it brings benefit to the village. It has also worked in the
same way, albeit rather more reluctantly, with the would-be developer of the 150-dwelling site
north of Coach Road and will continue to do so.
11. For the purpose of assessing the impact on the village, these two developments “in the
pipeline” totalling 250 dwellings must be considered together. PP34 would increase those
“pipeline developments” to 500, the impact of which on a village currently of around 1300 built
dwellings is deeply concerning. Removing the truly rural dwellings from this consideration, PP34
as it stands would bring about an increase of over 50% in urban dwellings in the parish. It is doubtful
that any amount of master-planning, as proposed in the policy, could mitigate the impact of such
a massive increase on village organisations and social life in such a relatively short time, especially
in a village which has no medical facilities of its own and where the three GP practices in adjacent
areas are already overloaded.
12. The impact of schools is also of concern. It is widely assumed that youngsters from Great
Horkesley are likely to be admitted to Trinity School in Chesterwell, an easy cycle ride from Coach
Road. In fact, the default secondary school for Great Horkesley is the St Helena School, some 4
miles from the PP34 site. Because its admission criteria are distance-based, Trinity School is already
reducing the proportion of pupils it takes from Great Horkesley. There is currently a bus route
between the village and St Helena school but journey times are (in the long experience of the
writer) unpredictable, especially for pupils wishing to take part in activities outside teaching hours.
13. The impact on the Bishop William Ward primary school in the village is also of concern. While
developers and the education authority will of course ensure that BWWS has the capacity to teach
children living in the new developments, the physical expansion of the school to accommodate the
children from 500 new homes will be massive. Once the “bulge” in pupil numbers resulting from
the new development has passed, there will be physical over-capacity in the village school which
the education authority will want to fill by bringing in children from outside the village. Even taking
into account the measures set out in the conditions of the 150-dwelling consent, if they are
enacted, this importing of pupils will exacerbate existing congestion and parking problems around
BWWS.
14. Finally, employment. There are two established employers in the village, a school
photographers and an agro-business growing and packaging onions for supermarkets; they are
unlikely to offer many new jobs as the village expands. There are other minor businesses on the
main road. In promoting a 400-home expansion of the village, it is surprising that the planning
authority did not identify the need to increase the amount of employment land within the village,
perhaps on one of the offered sites on or close to the main road. Reducing the need to travel to
work by fuelled vehicles and increasing the ability of people to walk or cycle to work should be at
the heart of a Local Plan. PP34 is silent on this, even though the 400-dwelling proposal is the 5th
largest in the whole of Colchester in emerging draft Plan.
Conclusion
15. Great Horkesley Parish Council remains open to reasonable proposals to provide additional
housing, recreational facilities including improved access to the countryside, and employment
opportunities provided that it is clear that no harm to the quality of life of the existing residents
will result and that appropriate mitigation of the impact of the development is feasible.
16. Having considered PP34 as it stands, GHPC takes the view that 400 new homes cannot be
provided on the site identified in PP34 without causing harms that cannot be mitigated, as set
out above, to the quality of life to those already living in the village and damage to the
countryside around it both directly within the Plan period and indirectly in the decades to come.
17. The number of new dwellings to be provided on the site identified in PP34 should be reduced
to 150, as per the outline planning consent already granted. The northernmost part of the site,
which is currently designated as open countryside, should be removed from the consultation
draft.
Please note: GHPC will conduct a Housing Needs Survey to demonstrate that the provision of 250
new dwellings on the land around Great Horkesley Manor and North of Coach Road is more than
enough to meet local demand for the foreseeable future. It will aim to share the results with the
planning authority before the results of the Regulation 18 consultation are put to elected
members.
CJA/January 2026P

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