Policy PP37 proposes scale of development that would increase the size of Langham by more than 250 percent, which is wholly disproportionate to its historic growth and established settlement hierarchy. Such a dramatic expansion risks serious harm to community cohesion, village identity, social sustainability. The policy does not demonstrate why this scale is appropriate for a rural village with limited services and employment opportunities. Without clear evidence that this level of growth is justified when compared to alternative locations, PP37 fails the soundness test of being justified and risks undermining the long term social and cultural fabric of the village.

Policy PP37 fails to demonstrate that the local highway network can safely accommodate the cumulative impacts of 900 new dwellings. School Road already experiences severe congestion and safety pressures during overlapping drop off and pick up times for Langham Primary School, Langham Preschool, and Oak School. Public transport provision is infrequent, unreliable, and insufficient to support sustainable travel choices, resulting in high car dependency. The policy does not provide robust evidence that transport mitigation is deliverable or effective, and therefore fails to meet the soundness test of being effective and consistent with sustainable transport objectives.

Policy PP37 does not adequately demonstrate that surface water drainage, foul sewer capacity, and wastewater treatment can be delivered without unacceptable environmental risk. Existing infrastructure is already under pressure, and the policy lacks clear evidence of deliverable upgrades or phased implementation. Increased surface water runoff and treated effluent discharge risk harm to flood resilience and the local river environment. Without a clear and funded water management strategy, the policy is not consistent with national planning policy requirements on flood risk, climate resilience, and protection of the natural environment.

This propose a scale of development that would increase the size of Langham by more than 250 percent, which is wholly disproportionate to its historic growth and established settlement hierarchy. Such a dramatic expansion risks serious harm to community cohesion, village identity, social sustainability. The policy does not demonstrate why this scale is appropriate for a rural village with limited services and employment opportunities. Without clear evidence that this level of growth is justified when compared to alternative locations, PP37 fails the soundness test of being justified and risks undermining the long term social and cultural fabric of the village.

Policy PP37 fails to demonstrate that the local highway network can safely accommodate the cumulative impacts of 900 new dwellings. School Road already experiences severe congestion and safety pressures during overlapping drop off and pick up times for Langham Primary School, Langham Preschool, and Oak School. Public transport provision is infrequent, unreliable, and insufficient to support sustainable travel choices, resulting in high car dependency. The policy does not provide robust evidence that transport mitigation is deliverable or effective, and therefore fails to meet the soundness test of being effective and consistent with sustainable transport objectives.

Policy PP37 does not adequately demonstrate that surface water drainage, foul sewer capacity, and wastewater treatment can be delivered without unacceptable environmental risk. Existing infrastructure is already under pressure, and the policy lacks clear evidence of deliverable upgrades or phased implementation. Increased surface water runoff and treated effluent discharge risk harm to flood resilience and the local river environment. Without a clear and funded water management strategy, the policy is not consistent with national planning policy requirements on flood risk, climate resilience, and protection of the natural environment.

Consultation Response: Infrastructure Provision, Phasing, and Settlement Impact
Preferred Options Local Plan – Regulation 18 (2025)
Policies concerned:
• PP37 – Land north of Park Lane, Langham
• PP9 – North-East Colchester
• PP18 – Land North of A120, Marks Tey Growth Area
• PP17 – Land South of A12, Marks Tey Growth Area
• PP10 – Land South of Berechurch Hall Road, Colchester
• PP19 – Land North of Oak Road, Tiptree
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General Comment – Infrastructure Capacity and Sustainable Growth
I am concerned that the scale of housing growth proposed across the above sites represents a very substantial increase in population, yet the Preferred Options Local Plan does not provide firm, binding commitments from infrastructure providers to ensure that essential services are delivered before development is occupied.
Although Strategic Policy ST7 refers to infrastructure provision and the preparation of an Infrastructure Delivery Plan (IDP), this approach relies heavily on future work, assumptions, and aspirations, rather than enforceable safeguards. Without clear delivery triggers, there is a significant risk that housing will be delivered ahead of infrastructure, placing unacceptable pressure on existing services and communities.
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Langham (PP37) – Scale, Character and Village Identity
In addition to infrastructure concerns, Policy PP37 raises a fundamental issue regarding the scale of development proposed at Langham.
Langham is a small rural village, with limited services, infrastructure, and employment opportunities. The scale of housing proposed would represent a disproportionate increase in population, fundamentally altering the character, role, and function of the village. This would risk transforming Langham from a rural settlement into a commuter extension of Colchester, without the infrastructure, services, or employment base to support such a change.
The proposal would:
• Place significant additional pressure on already limited local services
• Increase reliance on private car travel, contrary to sustainable transport objectives
• Erode the distinct rural character and settlement hierarchy that the Local Plan is intended to protect
• Create long-term sustainability issues that cannot be resolved through infrastructure funding alone
Even with improved infrastructure, the scale and nature of development proposed is not commensurate with the existing size, role, or capacity of Langham, and therefore raises concerns about soundness and consistency with sustainable development principles.
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Key Infrastructure Concerns Across All Sites
Across all six sites, there is insufficient certainty regarding provision for:
• Primary and secondary healthcare, including GP capacity
• Hospital services, particularly Colchester Hospital
• Education provision, including early years, primary and secondary school places
• Emergency services, including police, fire and ambulance response capacity
• Water supply and wastewater infrastructure, particularly given known water stress in North Essex
• Electricity and other utilities capacity
• Waste collection and disposal services
• Transport and accessibility, especially where growth is proposed in areas with limited public transport
Without firm commitments, these developments risk overburdening existing infrastructure and undermining community wellbeing.
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Site-Specific Sensitivities
While this response applies to all six sites, particular concerns include:
• PP9 – North-East Colchester: cumulative impacts on GP provision and Colchester Hospital
• PP17 & PP18 – Marks Tey Growth Areas: scale of growth relative to existing health, education, and service capacity
• PP19 – Tiptree: limited village infrastructure, including GP provision, schools and wastewater capacity
• PP37 – Langham: scale of development fundamentally changing the nature and sustainability of the village
• PP10 – Berechurch Hall Road: cumulative impacts from existing and planned development in South Colchester
Generic infrastructure policies are insufficient to address these location-specific issues.
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Required Changes to Make the Plan Sound
To ensure genuinely sustainable development, I request that the Local Plan is amended to include the following provisions for all six sites:
1. Infrastructure-First Policy Safeguards
Clear policy wording requiring that development does not commence or is not occupied unless the necessary supporting infrastructure has been secured, funded, and programmed for delivery.
2. Phased Housing Delivery Linked to Infrastructure Triggers
Each site policy should include explicit phasing limits, such that no more than an agreed number of dwellings can be occupied until:
• New or expanded GP facilities are operational
• Sufficient school places are available
• Water supply and wastewater upgrades are completed
• Emergency services confirm adequate capacity
3. Formal Commitments from Infrastructure Providers
Written confirmation should be required from:
• NHS Integrated Care Board and hospital trusts
• Essex County Council (education and highways)
• Essex Police
• Essex Fire & Rescue Service
• East of England Ambulance Service
• Anglian Water and other utility providers
Without such commitments, development should not proceed.
4. Site-Specific Infrastructure Schedules
Each policy (PP37, PP9, PP18, PP17, PP10 and PP19) should be supported by a clear infrastructure schedule setting out:
• What infrastructure is required
• Who will deliver it
• How it will be funded
• When it must be operational
• Which phase of housing it relates to
5. Use of Grampian-Style Conditions
The Plan should explicitly support Grampian planning conditions preventing occupation until off-site infrastructure is delivered and operational.
6. Ring-Fenced Developer Contributions
Developer contributions should be ring-fenced for the communities affected, with clear reporting on how and when funds are spent.
7. Water Stress and Wastewater Safeguards
No development should proceed without written confirmation that water supply and wastewater capacity are sufficient and will be delivered in advance of occupation.
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Conclusion
In its current form, the Preferred Options Local Plan does not provide sufficient certainty that infrastructure will be delivered in advance of housing growth across these sites. In the case of Langham, the scale of development proposed also risks fundamentally changing the nature of the village in a way that cannot be mitigated through infrastructure provision alone.
I therefore request that the Council strengthens Strategic Policy ST7 and amends Policies PP37, PP9, PP18, PP17, PP10 and PP19 to ensure that development is appropriately scaled, infrastructure-led, and supported by firm, enforceable commitments. This is essential to protect existing communities and to ensure sustainable development across the borough.

Langham Sewerage & Surface Water Drainage Current WRC status Langham’s WRC has operated above its current 420 cubic metres/day DWF permit for the majority of years between 2014 and 2024, as shown in table 1 below. Annual outturns have however fluctuated very widely, which reflects serious groundwater infiltration problems in the sewerage catchment network, causing large variations in flow rates dependent on local rainfall patterns each year. A £1m sewer relining project was therefore undertaken by AWS in 2015, resulting in some short-term infiltration reduction, but not enough to restore the WRC to DWF compliance over subsequent years. My uploaded document shows two different outturn results for each calendar year. The Q80 measure is the designated measure to be used when assessing whether there is available headroom for planning new housing growth within a WRC catchment area. The results below indicate non-compliance in 8 of the last 11 full years. In the last 5 full years, only one year (2022) was compliant, as a result of an exceptionally dry year with 30% less annual rainfall than usual. In November 2021, AWS submitted a pre-application to the Environment Agency for an increased DWF permit of 500 cubic metres/day, with a target implementation date of Dec 2024, as reported in a Committed Investment Plan submitted to Colchester’s Planning Authority. In reality, this pre-application was never progressed to a new permit application. AWS decided instead to focus efforts on further sewerage network surveys in the hope that additional groundwater infiltration reduction measures might reduce or even remove the requirement for an increased DWF permit. The reasons for this finally became apparent when AWS shared the following information with Langham Parish Council and our MP at a public meeting on 2nd February 2024: (i) A preliminary AWS costing exercise for upgrade or rebuild of the Langham WRC to meet an increased flow treatment capacity estimated the likely capital expenditure to be in excess of £6m.(ii) AWS’s Environmental Permit Scientist reported that Langham’s sewerage network has the worst groundwater infiltration rates in their entire estate of ~1100 WRC catchments, with the sole exception of 2 or 3 catchments in the low lying Norfolk Broads. Various surveys and flow monitoring activities have been undertaken by AWS throughout 2022, 2023 and 2024, but no evidence of any significant infiltration reduction opportunities and delivered solutions have thus far been reported back to Langham Parish Council. Langham WRC therefore remains flow non-compliant as clearly identified in CCC’s July 2025 Water Cycle Study. Consequently, and in line with current company policy, AWS’s current consultation advice to Colchester’s Planning Authority is that all planning applications in Langham should be refused due to lack of capacity at Langham WRC. The Water Cycle Study similarly recommends that “development coming forward…should be required to demonstrate available capacity at the WRC and the associated sewer network with AWS prior to submitting planning applications.” Current sewerage network status As reported above, AWS has recognised for over a decade that the Langham sewerage network has very serious groundwater infiltration problems, but has failed to make any significant progress in resolving them. These high levels of infiltration have the insidious consequence of “stealing” capacity from the flow permit and increasing the likelihood of DWF non-compliance, particularly during wet years. They also have the far more pernicious effect of causing hydraulic overload of the sewer network during periods of very wet weather. The results of this can range from sewage overspills from individual manholes, through to flooded streets and gardens, pumping station failures and ultimately internal sewage flooding of residential properties. This very worst case outcome has affected Langham in 2016 and again in 2024. Lesser incidents of street and garden sewage flooding have occurred many times over the last decade, with some residents’ gardens being submerged up to 6 times over the last 3 years. The CCC Water Cycle Study confirms (in table 4-3) that the CO4 postcode (comprising primarily Boxted, Langham and Highwoods) has suffered the highest prevalence of internal sewer flooding incidents across all of Colchester over the last 10 years, with more than 300 incidents recorded in official records. Langham’s sewer network is demonstrably operating with no flow headroom to cope with heavy rainfall events. Significant new housebuilding, together with increased wet weather variability from climate change, poses a very serious threat of disastrous sewage flooding incidents becoming far more frequent than at present. This is recognised in the Water Cycle Study’s recommendation that “development coming forward…should be required to demonstrate available capacity at the WRC and the associated sewer network with AWS prior to submitting planning applications.” What this recommendation means in Plain English is that any major new housing development at Langham will require not only a substantial upgrade to the Langham WRC, but also the installation of a new larger diameter and leak-free sewer network between the housing development site and the WRC Anglian Water investment requirements and timetable The Water Cycle Study confirms (in section 8.10) that AWS’s 2025-2030 business plan currently includes no investment at Langham WRC. It also notes an absence of any medium to long term solutions in the Drainage & Wastewater Management Plan covering the period out to 2050. It further notes that a WRC upgrade to protect water quality is technically achievable (to achieve thenecessary new permit requirements for ammonia, BOD and nitrates), but that “upgrades required may be significant”. The £6m cost estimate shared with Langham Parish Council in 2024 (prior to any proposals for over 1,000 new connected homes now envisaged in the draft Local Plan) almost certainly represents an absolute lower bound on the real costs that would need to be incurred to upgrade the WRC to the required capacity. It must also be noted that this cost estimate does not include any allowance for the cost of a new sewer network to serve the proposed large new housing development. Any such major revisions to AWS’s investment program will surely not be confirmed prior to formal adoption of the new Local Plan, currently targeted for May 2027. Subsequent delivery of the Langham WRC upgrade and new sewer network will surely take at least another 18 months after that, meaning that no planning applications for Langham can be brought forward until the beginning of 2029 at the earliest. The Water Cycle Study references the tension between this investment bottleneck and a stated desire by CCC to commence housebuilding at Langham and Boxted early in the Plan period. Section 9.2.1 specifically recognises these tensions and recommends further more detailed consultation around funding and timing so as to manage future delivery risks. This clearly highlights a significant deliverability risk with the proposed housing allocations in Langham and Boxted. Private sewerage solution feasibility The Water Cycle Study makes a brief mention of the “potential for inset providers to provide wastewater (and water supply infrastructure) outside of the AWS service area.” This is presumably a reference to the use of an independent NAV provider, as regulated by Ofwat, but with the same responsibilities as traditional water companies. This option may indeed allow for a faster implementation timetable, unconstrained by AWS’s 5 yearly strategic budget planning cycle. It also has the potential to offer a more cost competitive quotation for the large capital investment program required. If a NAV provider is to be appointed, however, they will need to liaise with the Environment Agency to agree permit requirements for discharge to the Black Brook, and these permit requirements will be driven by the same WFD water quality requirements, whoever the sewerage undertaker happens to be. Whilst the capital costs might be reduced somewhat by the NAV approach, they will still be very substantial, and a suitable alternative funding source will need to be identified, potentially impacting the viability of the 900 home development. Surface Water Drainage Provision of adequate surface water drainage is likely to be a very significant challenge to the proposed 900 home development, as a consequence of Langham’s high water table, flat topography and sole discharge pathway via the Black Brook. These challenges have already been clearly recognised in an adjacently located 30 home planning application (220595) which received outline planning permission in 2023. The application documents include a Site Specific Flood Risk & Sustainable Drainage Assessment report prepared by Richard Jackson Engineering Consultants. This report identifies the need for a large water storage basin to regulate surface water discharge rates towards the Black Brook. The required storage capacity was for this 30 home development was assessed as 200 cubic metres, to be implemented via a water storage basin with maximum water depth 0.75m and total surface area of 377 square metres.This strongly suggests that an extremely large water storage basin would be required to manage flood risks associated with a 900 home development: potentially larger than a full size professional football pitch, if ground conditions across the site are similar to those on the immediately adjacent site of planning application 220595. Such a large water storage basin raises a number of potential safety concerns, as well as viability concerns arising from the neutralisation of a significant amount of potential development land. Conclusion Sewage and drainage capacity issues in Langham present a very significant deliverability and commercial viability challenge to any large housing allocation in the village. These appear to have been seriously underestimated by Colchester’s Planning team. The draft site allocations should be reappraised with a view to redirecting growth to sites within the catchment areas of WRCs with available headroom to accommodate housing growth.

EXTREME MISMATCH WITH LOCAL HOUSING NEEDS Langham Parish Council’s professionally commissioned Housing Needs Survey and Housing Needs Assessment identify a genuine local requirement for only 60–120 new homes across the entire Local Plan period—nowhere near the 910 units proposed for the Langham allocation. The scale of development being suggested is therefore wholly disproportionate to locally evidenced need. Given Langham’s significant price premium over urban Colchester, the “Langham910” would inevitably be marketed primarily to households relocating from London rather than meeting local demand. This would generate a large influx of long distance commuters, increasing car dependency and traffic pressures. Such an outcome does nothing to address Colchester City Council’s affordable housing challenges and risks exacerbating existing sustainability issues rather than resolving them.

Commercial Viability Concerns The strategic viability assessments prepared by Newmark on behalf of Colchester City Council rely heavily on generic, high level assumptions applied uniformly across all twelve strategic sites. These include standardised figures for S106 contributions per unit and broad-brush allowances for infrastructure and abnormal costs. Such an approach may be convenient at a strategic level, but it fails to reflect the substantial site specific constraints present at Langham. Given the absence of detailed, site specific modelling, it is highly probable that key cost elements—particularly those relating to foul drainage upgrades, sewerage capacity, and necessary highways interventions—have been significantly underestimated. These are not optional enhancements but fundamental prerequisites for safe and sustainable development. Compounding this issue is the lack of a Langham specific Infrastructure Delivery Plan. Without a clear, costed, and deliverable infrastructure strategy, it is impossible to demonstrate that the site is commercially viable or capable of supporting the level of development proposed.

Non‑Deliverability of the Proposed Allocation The proposed allocation contains numerous internal contradictions and unresolved constraints. Even if each issue were considered in isolation and theoretically capable of mitigation, the combined effect of these constraints creates a level of uncertainty that is fundamentally incompatible with the National Planning Policy Framework (NPPF) definition of a deliverable site. Under the NPPF, a site is only considered deliverable where it is available now, is in a suitable location for development, and where there is a realistic prospect that housing will be delivered within the next five years. This proposal fails to meet these criteria. Significant barriers—including fragmented land ownership, operational constraints associated with the adjacent airfield, longstanding and unresolved foul drainage and sewage capacity issues, and unsafe or substandard junctions onto the A12—collectively undermine any realistic prospect of delivery within the required timeframe. These are not minor technical matters but fundamental constraints that have persisted for years without resolution. Given the scale and persistence of these issues, it is difficult to see how the site could credibly be considered deliverable within five years. It would be prudent for the Council to acknowledge this at the plan‑making stage, rather than proceed on assumptions that are unlikely to withstand scrutiny. Doing so would avoid unnecessary expenditure of time, resources, and public money.

NON-COMPLIANCES WITH NATIONAL PLANNING POLICY FRAMEWORK (NPPF) The draft Langham allocation aligns particularly poorly with the following NPPF 2024 paragraphs: 11a; 16a-c; 20a-d; 22; 35; 36b-d; 77; 92; 98; 100; 105; 108; 109; 110; 124; 129c-d; 132; 135c; 161; 187b; 189; 192; 198; 212; 213. NPPF 11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that: a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects; NPPF 16. Plans should: a) be prepared with the objective of contributing to the achievement of sustainable development; b) be prepared positively, in a way that is aspirational but deliverable; c) be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees. NPPF 20. Strategic policies should set out an overall strategy for the pattern, scale and design quality of places (to ensure outcomes support beauty and placemaking), and make sufficient provision for: a) housing (including affordable housing), employment, retail, leisure and other commercial development; b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat); c) community facilities (such as health, education and cultural infrastructure); and d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation. NPPF 22. Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. NPPF 35. Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. NPPF 36. Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. NPPF 77. The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Working with the support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way. NPPF 92. When considering edge of centre and out of centre proposals, preference should be given to accessible sites which are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale, so that opportunities to utilise suitable town centre or edge of centre sites are fully explored. NPPF 98. To provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: a) plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments; b) take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community; c) guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs; d) ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community; and e) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. NPPF 100. It is important that a sufficient choice of early years, school and post-16 places are available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education. They should: a) give great weight to the need to create, expand or alter early years, schools and post-16 facilities through the preparation of plans and decisions on applications; and b) work with early years, school and post-16 promoters, delivery partners and statutory bodies to identify and resolve key planning issues before applications are submitted. NPPF 105. Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails. NPPF 109. Transport issues should be considered from the earliest stages of plan-making and development proposals, using a vision-led approach to identify transport solutions that deliver well-designed, sustainable and popular places. This should involve: a) making transport considerations an important part of early engagement with local communities; b) ensuring patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places; c) understanding and addressing the potential impacts of development on transport networks; d) realising opportunities from existing or proposed transport infrastructure, and changing transport technology and usage – for example in relation to the scale, location or density of development that can be accommodated; e) identifying and pursuing opportunities to promote walking, cycling and public transport use; and f) identifying, assessing and taking into account the environmental impacts of traffic and transport infrastructure – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains. NPPF 110. The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making. NPPF 124. Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land. NPPF 129. Planning policies and decisions should support development that makes efficient use of land, taking into account: a) the identified need for different types of housing and other forms of development, and the availability of land suitable for accommodating it; b) local market conditions and viability; c) the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use; d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and e) the importance of securing well-designed, attractive and healthy places. NPPF 132. Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics. Neighbourhood planning groups can play an important role in identifying the special qualities of each area and explaining how this should be reflected in development, both through their own plans and by engaging in the production of design policy, guidance and codes by local planning authorities and developers. NPPF 135. Planning policies and decisions should ensure that developments: a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development; b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping; 40 c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities); d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit; e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users51; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience. NPPF 161. The planning system should support the transition to net zero by 2050 and take full account of all climate impacts including overheating, water scarcity, storm and flood risks and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure. NPPF 187. Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate; d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures and incorporating features which support priority or threatened species such as swifts, bats and hedgehogs; e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. NPPF 189. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. NPPF 192. To protect and enhance biodiversity and geodiversity, plans should: a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity. NPPF 198. Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. In doing so they should: a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life72; 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. NPPF 212. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm total loss or less than substantial harm to its significance. NPPF 213. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional. environment Decarbonisation of the transport sector should be promoted and implemented

NON-COMPLIANCE WITH COLCHESTER CITY COUNCIL’s TRANSPORT MODAL SHIFT IMPERATIVE The large draft Langham housing allocation runs totally counter to Colchester City Council’s well documented and self-acknowledged challenging modal shift imperative. Ambitious modal shift programs will be most effective in sustainable locations close to local services. In Langham, their effect will be marginal at best, as recognised in the October 2025 update to the Transport Evidence. As National Highways also state in their Oct 2023 Planning for the Future guide: “where developments are located, how they are designed and how well delivery and public transport services are integrated has a huge impact on people’s mode of transport for short journeys”. But not on longer journeys from remote rural locations such as Langham, one can safely infer. The large draft Langham housing allocation also runs counter to many other strategic policy documents referenced in Colchester City Council’s Transport Evidence. National Highways’ Planning for the Future Guide (Oct 2023) states that “NH will therefore expect those responsible for preparing local and neighbourhood plans to only promote development at locations that are or can be made sustainable and where opportunities to maximise walking, wheeling, cycling, public transport and shared travel have been identified.” The Transport East Transport Strategy (2023-2050) sets the following first two goals: Goal 1: Reduce demand for carbon intensive transport trips through local living by making it easier for people to access services locally or by digital means. Goal 2: Shift modes by supporting people to switch from private car to active travel, shared and passenger transport, and goods to more sustainable modes like rail. The Essex County Council Climate Action Plan outlines the Avoid Shift Improve approach: Avoiding unnecessary motor vehicle trips Encouraging residents to shift to sustainable modes such as walking, cycling and public transport Improving the efficiency and sustainability of essential journeys through initiatives focused on improving bus provision The Essex County Council Local Transport Plan, currently still being drafted for LTP4, aims that: People and goods can get where they need to go efficiently and sustainably Everyone should have good sustainable access to work, education and training, essential services and leisure activities, wherever in the county they live Investment should focus on ways to travel which protect and enhance the local enhance the local environment.

NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s CLIMATE AND NET-ZERO GOALS Designed-in car dependency will exacerbate carbon dioxide emissions The typical UK personal carbon dioxide budget currently comprises 22% from personal transport, and 14% from home electricity and heating (the remaining components being 29% good & services, 17% food, 7% aviation, and 11% other). Colchester City Council’s Feb 2025 Transport Evidence Report identifies Langham within one of Colchester’s two least sustainable MSOA(*) geographies (along with West Mersea). The Langham MSOA exhibits Colchester’s highest car transport mode share of 77.91% (compared with typical figures of 40-60% in the urban parts of Colchester). (*: MSOA = Middle Layer Super Output Area, a medium–sized statistical geography used in transport planning and socio-economic research). Building 910 new homes in Langham will likely add approaching 2,000 additional heavily used cars to the highest car-use MSOA (MSOA 001) in Colchester. Mitigation projects to encourage Active travel will be expensive (if funded) and largely ineffective The journey distances to Colchester Mainline Station (5.8 miles) and Manningtree Station (5.8 miles) are too great to encourage any modal shift to cycling, for rail commuters. The shorter 2.8 miles journey distance to the northern end of Rapid Transit System may encourage some limited modal shift for commuting into Colchester, but only with provision of a dedicated and expensive cycleway connection that avoids the perilous current rat run along Langham Lane. Such a åascheme is proposed within the infrastructure project schedule, with an indicative cost of £9m and indicative timing of 2034-37, but with no funding secured and it is hard to imagine that such a scheme will prove cost effective, functionally effective and therefore deliverable in these timescales. Any positive climate impacts of Net Zero homebuilding standards will be more than offset by negative climate impacts from increased road transport. Colchester City Council’s net-zero policies exhibit a clear imbalance between home and transport measures to reduce Carbon dioxide emissions. Policies NZ1 and NZ2 demand expensive net zero homebuilding standards on the grounds that Building Regulations 2021 and Future Homes Standard 2025 “do not adequately address operational or embodied carbon emissions from new development…it therefore falls to the planning system to ensure new development addresses carbon emissions in a way that aligns with local and national climate targets.” But there is no correspondingly high ambition to properly address the more significant personal transport based carbon emissions, which actually generate a substantially larger contribution to overall carbon budgets. Colchester City Council’s net-zero policies are therefore clearly not optimised to address local and national climate targets effectively. They should be fundamentally reviewed to seek a more balanced approach. Negative impacts will arise not only from the direct additional Langham traffic generation, but also increased emissions from extra congestion delays at the A12/A120 junction and the main Ipswich Road route into and out of Colchester (both of which will be heavily loaded by extra traffic emanating from a strategic Langham housing allocation). All of Colchester City Council’s Transport Modelling work is indicative of worsening congestion problems in many areas of the City, including the A12/A120 junction and the Ipswich Road, even with ambitious modal shift programs. More congestion and travel delays means more carbon emissions.

In relation to justification and lauding oof the proposed housing development near the Park and Ride I found on CCC website a quote from Cllr Julie Young “Too many families in Colchester are living in temporary accommodation or struggling to find a home that meets their needs. By bringing these plots to market, we’re taking a real step toward changing that. This is about using council-owned land to create homes that people can actually afford – homes that are close to jobs, schools, and transport links. Northern Gateway isn’t just a development site; it’s a chance to build a community where people feel secure, supported and connected to the rest of the city.” The proposal development for Langham is NOT CLOSE TO JOBS NOT CLOSE TO SCHOOLS NOT NEAR TO MEDICAL FACILITIES NOT NEAR TO TRANSPORT LINKS - Langham is at least 8 miles from the city centre and approximately 6 miles from the major commuting railway link. NOT CONNECTED TO THE CITY - FAR FROM IT -- Langham is at least 8 miles from the city centre and approximately 6 miles from the major commuting railway link. WILL NOT BUILD A COMMUNITY - it will be a suburban imposition and destroyer of a small village

LACK OF PLAN WITH FUNDING PROPOSALS TO DELIVER ESSENTIAL INFRASTRUCTURE UPGRADES In Langham there is a longstanding and well documented problem of overloaded sewage treatment works and sewer network. In September 2017, Colchester Borough Council, Anglian Water and the Environment Agency signed a Joint Position Statement following the publication of the December 2016 Water Cycle Study. This report recommended that new housing growth needed to be phased in line with infrastructure improvements to ensure that Langham WRC could provide the increased capacity required. In practice, no such infrastructure improvements have been implemented over the 8 years since then, and as a result the 80 Langham homes included in the current Local Plan have stalled with only 23 of the homes being built so far. Properties in Langham have suffered internal sewage flooding in 2016 and again in 2024, and three public meetings have been held in Langham between 2022 and 2024, with Anglian Water and our MP in attendance on each occasion. Our MP wrote to the CEO of Anglian Water in February 2024 requesting urgent remedial action, but to no avail. It has since become apparent (and has been confirmed in the new Water Cycle Study) that Anglian Water have no strategic investment plans for Langham WRC between now and 2050. There is NO credible and costed plan to deliver a legally compliant sewage treatment facility for any new homes, let alone over 1,100 homes (including the Boxted draft allocation of 150 and the unbuilt 57 homes from the current Local Plan) Anglian Water’s current Drainage and Wastewater Management Plan (published in May 2023 on a five yearly refresh cycle) confirms that there are no short medium, or long term upgrade plans for Langham WRC through the entire designated strategic planning timeframe right out to 2050. There is NO serious plans to resolve this showstopper identified anywhere within Colchester City Councils’ Evidence Base for the draft new Local Plan. Newmark’s strategic site viability assessment notes that “Extra sewage infrastructure will be required on site due to limited existing capacity; Anglian Water will require an onsite solution.” This statement is seriously ill-informed. The Environment Agency have confirmed in writing to Langham Parish Council that onsite sewage solutions are never permitted for developments of more than a handful of houses. This position is also clearly stated in the EA’s Foul Drainage assessment form FDA1. There is NO credible and costed plan to deliver essential local road safety upgrades to support road traffic growth. Colchester City Council’s infrastructure project schedule spreadsheet (Appendix A to the infrastructure audit and delivery plan stage 3 Report Updated) contains no identified highways upgrade projects associated with the strategic Langham site. This is a serious oversight. A number of significant upgrades will certainly be required, starting with the A12 northbound exit from the A12 into Park Lane. This is an unnumbered junction which involves a sharp turn of approximately 110 degrees into a narrow country lane (Park Lane), cutting across the exit lane from the Shell petrol station onto the northbound main A12 dual carriageway. This means that traffic exiting the A12 into Langham via Park Lane is already very dangerous as the same stretch of road that is used for decelerating traffic from the A12 competing with accelerating traffic from the petrol station and crossing each other. The 110 degree turn is already a highly dangerous junction, subject to at least two accidents in recent years, where cars leaving the A12 have failed to make the turn successfully and have crashed into the Langham property closest to the A12. We understand that a Starbucks is planned to be constructed at the petrol station site. This will substantially increase the volume of traffic involved in this dangerous manoeuvre further adding to the overall increase in traffic should this development proceed. As a result of these issues this junction will need a major re-design and be massively upgraded to improve road safety with the dramatic increase in local traffic entering Langham. Traffic entering the village from the southbound A12 carriageway turns immediately along Birchwood Road to a T junction Birchwood Road/Wick Road which is a small village junction with parked cars and vans restricting view in all directions. Which such a massive increase in population this would become a busy and inadequate junction. Upgrade will be needed, which is likely impossible due to houses positioned all around it. A more seriously dangerous junction is where the traffic from Birchwood Road/Wick Road turns right and meets the Wick Road/Park Lane junction. This junction is where the above mentioned traffic meets the traffic that has entered Park Lane from the A12 Northbound traffic that I have also already mentioned. This is already a dangerous junction where accidents have occurred previously. It is a very busy junction as traffic travelling north from Colchester up the A12 in the direction of Ipswich travel through Langham via Park Lane Park. It is a “rat run” especially at peak times. If the population of Langham is increased as suggested, and exiting on to Park Lane as planned, traffic on Park Lane will increase further, exacerbating the current position to the point of increased possibility of accidents, and potential traffic volume problems in the village. Speeding along Park Lane is also currently a serious problem. A major upgrade to this junction will be required at considerable cost. Park Lane, Moor Road and School Road currently have limited pavement provision, and traffic growth associated with 900 new homes will make pavement provision essential on these roads bordering the new development site. At the other end of the village there is likely to an issue at Park Lane/ Langham Lane as use of the junction substantially increases. As per other junctions in the village this is a small rural T junction not deigned to cope with the increased volumes that will ensue. This might also require an upgrade. It would be inappropriate of me to mention the infamous damaged Severalls Lane bridge over the A12, which has remained unrepaired for over six years now since the introduction of single lane operation under traffic light control? This road provides the primary local distributor road connecting Colchester with Langham and Boxted, and it will not be able to cope with the increased traffic from over 1100 new homes. Langham lane is constantly in need of repair at its perimeters. It is not designed to cope with its current volume and type of vehicles. There are no verges, no lighting, and multiple potholes. CCC promote greener travel, including bicycles. It is already very dangerous to cycle along Langham Lane to and from Colchester which renders cycling dangerous and not desirable at the present time, and it is highly unlikely that new residents would take that option with widening or general upgrade of the lane, which will lead to increased Langham/Colchester car traffic contrary to any green aspirations. There is NO credible and costed plan to manage projected increased on the A12 and Ipswich Road traffic congestion arising from this draft strategic site allocation. It is extremely unclear from the Transport and Further Transport Evidence reports whether or not the impact of 1100 new homes has been properly assessed in respect of congestion at A12 Junction 29 and the Ipswich Road leading into Colchester.

ENVIRONMENTAL DAMAGE There will be a loss of 40 hectares of prime Grade 2 agricultural land Colchester City council appears not to publish or track any statistics about agricultural land use shares and trends across its area, which is disappointing in the national context of monitoring trends in UK food production security (eg. The UK Food Security Index introduced by DEFRA in 2024). Severing of a recognised wildlife habitat corridor including rare bat species, nightingales and skylarks Roughly half of the proposed development site sits within various Strategic Opportunities areas designated in the Greater Essex Local Nature Recovery Strategy. Ecological surveys undertaken for recent small developments adjacent to the proposed large new development site have identified and observed 5 different bat species, nightingales, skylarks and badgers among other species. The mature hedgerows running through the site provide extensive habitat support, and whilst it is proposed to retain most or all of these hedges, the habitat disruption both during construction and afterwards (when the hedgerow habitats will have become fragmented and disconnected) will be severe. Increased effluent pollution damage to Black Brook and downstream River Stour . At a February 2024 public meeting in Langham (attended by our MP) Anglian Water formally confirmed that the Langham sewerage catchment area suffered from extreme levels of groundwater infiltration. The worst in their entire network in fact, barring a handful of low-lying catchments in the Norfolk Broads. As a result, wet weather periods lead to hydraulic overload causing sewage flooding incidents both in Langham village and at the WRC itself, where overflows pass directly into the Black Brook without going through all the treatment tanks. APPENDIX 6: LANGHAM WRC COMPLIANCE INSPECTION REPORT provides an example of this, in a report issued by the Environment Agency following a routine inspection visit in December 2023. The Black Brook water quality was tested in September 2025 as part of the Great UK Water Blitz citizen science program, at a location some 800m downstream of the WRC discharge point. The results showed very high levels of nitrate (5-10 mg/L) and phosphate (0.2-0.5mg/L) pollution. This is highly suggestive of human sewage pollution from the WRC (given that the upstream Black Brook does not sit close to many agricultural fields subject to fertiliser run-off). The Black Brook is a tributary of the River Stour, which it connects to in Dedham, very close to a water abstraction zone (SPZ1)

LANGHAM IS UNSUITABLE/UNSUSTAINABLE LOCATION FOR MAJOR HOUSING GROWTH The proposal is totally disproportionate to the existing community, infrastructure and amenities. Langham parish currently has 473 residential properties of which circa 350 are within the core village and the remaining 120-odd houses situated more remotely in the surrounding rural countryside. The proposed development would therefore increase the residential stock in Langham Moor and Wick from 350 houses to 1260 houses, representing a growth ratio of 360% in housing stock. The corresponding population growth ratio would almost certainly exceed 400%. The existing limited local village facilities will be totally overwhelmed by this level of population growth. These existing facilities (Community Centre, volunteer-run Community Shop, Pre-School, Recreation Ground and Children’s Play Area)) are all located along School Road outside the northern boundary of the proposed development. Any provision of alternative new more centrally located facilities would inevitably disrupt and threaten the ongoing viability of these current facilities. Comparing draft policies PP9 (North-East Colchester, 2,000 homes) and PP37 (Langham, 900 new homes) it becomes clear that there are no plans to build a new local centre in Langham, whereas in NE Colchester, policy PP9 para d) proposes “Provision of a new local centre to serve the new and existing local community, this may include provision of retail, commercial and community facilities at an appropriate scale, relevant to the role and function of a local centre and the communities it is intended to serve”. This absence of any suitable local centre in Langham will exacerbate the existing high car dependency within the village: for work commuting, school runs, shopping access, healthcare access and other services access. CCC’s February 2025 Transport Evidence Report recognises the following NPPF mandated key transport principles: PRIORITISING SUSTAINABLE MODES: The NPPF encourages planning decisions that prioritise walking, cycling, and public transport over car travel REDUCING RELIANCE ON CARS: Developments should be designed to minimise the need for car travel by locating them close to existing services, amenities, and transport infrastructure IMPROVING ACCESSIBILITY: New developments should be well-connected to public transport networks, cycle lanes, and pedestrian routes ADDRESSING TRAVEL DEMAND: Planning applications should assess the potential transport impacts of the development and propose measures to mitigate any negative effects Addressing Travel Demand: Planning applications should assess the potential transport impacts of the development and propose measures to mitigate any negative effects. The does not meet the test of any of the above principles. The development will not only impact Langham negatively; it will have an adverse effect on setting of adjacent Dedham Vale National Landscape where one third of the land area of Langham Parish sits within the Dedham Vale National Landscape, and the proposed site sits within 400m of the boundary on the eastern side, and within 800m of the boundary on the northern side. Another point on unsuitability is the Boxted airfield. The proposal is incompatible with NPPF (para 111f) requirement for Planning policies to recognise the importance of maintaining a national network of general aviation airfields in accordance with the Government’s General Aviation Strategy. Of interest is the work undertaken by Newmark for CCC that states as a site strength that “Minimal abnormal costs identified” and “National Highways have expressed no concerns”. Noting the many very real infrastructure issues this statement from Newmark strongly suggests a lack of due diligence in their strategic site assessment.

(c) Langham Lane will need to be made fit for purpose. Widening to incorporate a cycle lane (to satisfy green credentials), properly repaired to cope with more traffic, probably requiring kerbs to prevent collapsing/potholes at the edges, all of which will be extremely expensive, even if possible. CPOs will be needed for increased land requirement. The A12 exit is not a proper junction (not even numbered), with a short deceleration lane and then 90 degrees into a narrow Park Lane. This will require a huge upgrade as Langham becomes a substantial conurbation. Houses will need to be CPO and demolished.

Langham Sewerage & Surface Water Drainage Current WRC status Langham’s WRC has operated above its current 420 cubic metres/day DWF permit for the majority of years between 2014 and 2024, as shown in table 1 below. Annual outturns have however fluctuated very widely, which reflects serious groundwater infiltration problems in the sewerage catchment network, causing large variations in flow rates dependent on local rainfall patterns each year. A £1m sewer relining project was therefore undertaken by AWS in 2015, resulting in some short-term infiltration reduction, but not enough to restore the WRC to DWF compliance over subsequent years. My uploaded document shows two different outturn results for each calendar year. The Q80 measure is the designated measure to be used when assessing whether there is available headroom for planning new housing growth within a WRC catchment area. The results below indicate non-compliance in 8 of the last 11 full years. In the last 5 full years, only one year (2022) was compliant, as a result of an exceptionally dry year with 30% less annual rainfall than usual. In November 2021, AWS submitted a pre-application to the Environment Agency for an increased DWF permit of 500 cubic metres/day, with a target implementation date of Dec 2024, as reported in a Committed Investment Plan submitted to Colchester’s Planning Authority. In reality, this pre-application was never progressed to a new permit application. AWS decided instead to focus efforts on further sewerage network surveys in the hope that additional groundwater infiltration reduction measures might reduce or even remove the requirement for an increased DWF permit. The reasons for this finally became apparent when AWS shared the following information with Langham Parish Council and our MP at a public meeting on 2nd February 2024: (i) A preliminary AWS costing exercise for upgrade or rebuild of the Langham WRC to meet an increased flow treatment capacity estimated the likely capital expenditure to be in excess of £6m.(ii) AWS’s Environmental Permit Scientist reported that Langham’s sewerage network has the worst groundwater infiltration rates in their entire estate of ~1100 WRC catchments, with the sole exception of 2 or 3 catchments in the low lying Norfolk Broads. Various surveys and flow monitoring activities have been undertaken by AWS throughout 2022, 2023 and 2024, but no evidence of any significant infiltration reduction opportunities and delivered solutions have thus far been reported back to Langham Parish Council. Langham WRC therefore remains flow non-compliant as clearly identified in CCC’s July 2025 Water Cycle Study. Consequently, and in line with current company policy, AWS’s current consultation advice to Colchester’s Planning Authority is that all planning applications in Langham should be refused due to lack of capacity at Langham WRC. The Water Cycle Study similarly recommends that “development coming forward…should be required to demonstrate available capacity at the WRC and the associated sewer network with AWS prior to submitting planning applications.” Current sewerage network status As reported above, AWS has recognised for over a decade that the Langham sewerage network has very serious groundwater infiltration problems, but has failed to make any significant progress in resolving them. These high levels of infiltration have the insidious consequence of “stealing” capacity from the flow permit and increasing the likelihood of DWF non-compliance, particularly during wet years. They also have the far more pernicious effect of causing hydraulic overload of the sewer network during periods of very wet weather. The results of this can range from sewage overspills from individual manholes, through to flooded streets and gardens, pumping station failures and ultimately internal sewage flooding of residential properties. This very worst case outcome has affected Langham in 2016 and again in 2024. Lesser incidents of street and garden sewage flooding have occurred many times over the last decade, with some residents’ gardens being submerged up to 6 times over the last 3 years. The CCC Water Cycle Study confirms (in table 4-3) that the CO4 postcode (comprising primarily Boxted, Langham and Highwoods) has suffered the highest prevalence of internal sewer flooding incidents across all of Colchester over the last 10 years, with more than 300 incidents recorded in official records. Langham’s sewer network is demonstrably operating with no flow headroom to cope with heavy rainfall events. Significant new housebuilding, together with increased wet weather variability from climate change, poses a very serious threat of disastrous sewage flooding incidents becoming far more frequent than at present. This is recognised in the Water Cycle Study’s recommendation that “development coming forward…should be required to demonstrate available capacity at the WRC and the associated sewer network with AWS prior to submitting planning applications.” What this recommendation means in Plain English is that any major new housing development at Langham will require not only a substantial upgrade to the Langham WRC, but also the installation of a new larger diameter and leak-free sewer network between the housing development site and the WRC Anglian Water investment requirements and timetable The Water Cycle Study confirms (in section 8.10) that AWS’s 2025-2030 business plan currently includes no investment at Langham WRC. It also notes an absence of any medium to long term solutions in the Drainage & Wastewater Management Plan covering the period out to 2050. It further notes that a WRC upgrade to protect water quality is technically achievable (to achieve thenecessary new permit requirements for ammonia, BOD and nitrates), but that “upgrades required may be significant”. The £6m cost estimate shared with Langham Parish Council in 2024 (prior to any proposals for over 1,000 new connected homes now envisaged in the draft Local Plan) almost certainly represents an absolute lower bound on the real costs that would need to be incurred to upgrade the WRC to the required capacity. It must also be noted that this cost estimate does not include any allowance for the cost of a new sewer network to serve the proposed large new housing development. Any such major revisions to AWS’s investment program will surely not be confirmed prior to formal adoption of the new Local Plan, currently targeted for May 2027. Subsequent delivery of the Langham WRC upgrade and new sewer network will surely take at least another 18 months after that, meaning that no planning applications for Langham can be brought forward until the beginning of 2029 at the earliest. The Water Cycle Study references the tension between this investment bottleneck and a stated desire by CCC to commence housebuilding at Langham and Boxted early in the Plan period. Section 9.2.1 specifically recognises these tensions and recommends further more detailed consultation around funding and timing so as to manage future delivery risks. This clearly highlights a significant deliverability risk with the proposed housing allocations in Langham and Boxted. Private sewerage solution feasibility The Water Cycle Study makes a brief mention of the “potential for inset providers to provide wastewater (and water supply infrastructure) outside of the AWS service area.” This is presumably a reference to the use of an independent NAV provider, as regulated by Ofwat, but with the same responsibilities as traditional water companies. This option may indeed allow for a faster implementation timetable, unconstrained by AWS’s 5 yearly strategic budget planning cycle. It also has the potential to offer a more cost competitive quotation for the large capital investment program required. If a NAV provider is to be appointed, however, they will need to liaise with the Environment Agency to agree permit requirements for discharge to the Black Brook, and these permit requirements will be driven by the same WFD water quality requirements, whoever the sewerage undertaker happens to be. Whilst the capital costs might be reduced somewhat by the NAV approach, they will still be very substantial, and a suitable alternative funding source will need to be identified, potentially impacting the viability of the 900 home development. Surface Water Drainage Provision of adequate surface water drainage is likely to be a very significant challenge to the proposed 900 home development, as a consequence of Langham’s high water table, flat topography and sole discharge pathway via the Black Brook. These challenges have already been clearly recognised in an adjacently located 30 home planning application (220595) which received outline planning permission in 2023. The application documents include a Site Specific Flood Risk & Sustainable Drainage Assessment report prepared by Richard Jackson Engineering Consultants. This report identifies the need for a large water storage basin to regulate surface water discharge rates towards the Black Brook. The required storage capacity was for this 30 home development was assessed as 200 cubic metres, to be implemented via a water storage basin with maximum water depth 0.75m and total surface area of 377 square metres.This strongly suggests that an extremely large water storage basin would be required to manage flood risks associated with a 900 home development: potentially larger than a full size professional football pitch, if ground conditions across the site are similar to those on the immediately adjacent site of planning application 220595. Such a large water storage basin raises a number of potential safety concerns, as well as viability concerns arising from the neutralisation of a significant amount of potential development land. Conclusion Sewage and drainage capacity issues in Langham present a very significant deliverability and commercial viability challenge to any large housing allocation in the village. These appear to have been seriously underestimated by Colchester’s Planning team. The draft site allocations should be reappraised with a view to redirecting growth to sites within the catchment areas of WRCs with available headroom to accommodate housing growth.

EXTREME MISMATCH WITH LOCAL HOUSING NEEDS Langham Parish Council’s professionally commissioned Housing Needs Survey and Housing Needs Assessment identify a genuine local requirement for only 60–120 new homes across the entire Local Plan period—nowhere near the 910 units proposed for the Langham allocation. The scale of development being suggested is therefore wholly disproportionate to locally evidenced need. Given Langham’s significant price premium over urban Colchester, the “Langham910” would inevitably be marketed primarily to households relocating from London rather than meeting local demand. This would generate a large influx of long distance commuters, increasing car dependency and traffic pressures. Such an outcome does nothing to address Colchester City Council’s affordable housing challenges and risks exacerbating existing sustainability issues rather than resolving them.

Commercial Viability Concerns The strategic viability assessments prepared by Newmark on behalf of Colchester City Council rely heavily on generic, high level assumptions applied uniformly across all twelve strategic sites. These include standardised figures for S106 contributions per unit and broad-brush allowances for infrastructure and abnormal costs. Such an approach may be convenient at a strategic level, but it fails to reflect the substantial site specific constraints present at Langham. Given the absence of detailed, site specific modelling, it is highly probable that key cost elements—particularly those relating to foul drainage upgrades, sewerage capacity, and necessary highways interventions—have been significantly underestimated. These are not optional enhancements but fundamental prerequisites for safe and sustainable development. Compounding this issue is the lack of a Langham specific Infrastructure Delivery Plan. Without a clear, costed, and deliverable infrastructure strategy, it is impossible to demonstrate that the site is commercially viable or capable of supporting the level of development proposed.

Non‑Deliverability of the Proposed Allocation The proposed allocation contains numerous internal contradictions and unresolved constraints. Even if each issue were considered in isolation and theoretically capable of mitigation, the combined effect of these constraints creates a level of uncertainty that is fundamentally incompatible with the National Planning Policy Framework (NPPF) definition of a deliverable site. Under the NPPF, a site is only considered deliverable where it is available now, is in a suitable location for development, and where there is a realistic prospect that housing will be delivered within the next five years. This proposal fails to meet these criteria. Significant barriers—including fragmented land ownership, operational constraints associated with the adjacent airfield, longstanding and unresolved foul drainage and sewage capacity issues, and unsafe or substandard junctions onto the A12—collectively undermine any realistic prospect of delivery within the required timeframe. These are not minor technical matters but fundamental constraints that have persisted for years without resolution. Given the scale and persistence of these issues, it is difficult to see how the site could credibly be considered deliverable within five years. It would be prudent for the Council to acknowledge this at the plan‑making stage, rather than proceed on assumptions that are unlikely to withstand scrutiny. Doing so would avoid unnecessary expenditure of time, resources, and public money.

NON-COMPLIANCES WITH NATIONAL PLANNING POLICY FRAMEWORK (NPPF) The draft Langham allocation aligns particularly poorly with the following NPPF 2024 paragraphs: 11a; 16a-c; 20a-d; 22; 35; 36b-d; 77; 92; 98; 100; 105; 108; 109; 110; 124; 129c-d; 132; 135c; 161; 187b; 189; 192; 198; 212; 213. NPPF 11. Plans and decisions should apply a presumption in favour of sustainable development. For plan-making this means that: a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects; NPPF 16. Plans should: a) be prepared with the objective of contributing to the achievement of sustainable development; b) be prepared positively, in a way that is aspirational but deliverable; c) be shaped by early, proportionate and effective engagement between planmakers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees. NPPF 20. Strategic policies should set out an overall strategy for the pattern, scale and design quality of places (to ensure outcomes support beauty and placemaking), and make sufficient provision for: a) housing (including affordable housing), employment, retail, leisure and other commercial development; b) infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat); c) community facilities (such as health, education and cultural infrastructure); and d) conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation. NPPF 22. Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. NPPF 35. Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. NPPF 36. Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant. NPPF 77. The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes). Working with the support of their communities, and with other authorities if appropriate, strategic policy-making authorities should identify suitable locations for such development where this can help to meet identified needs in a sustainable way. NPPF 92. When considering edge of centre and out of centre proposals, preference should be given to accessible sites which are well connected to the town centre. Applicants and local planning authorities should demonstrate flexibility on issues such as format and scale, so that opportunities to utilise suitable town centre or edge of centre sites are fully explored. NPPF 98. To provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should: a) plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments; b) take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community; c) guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs; d) ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community; and e) ensure an integrated approach to considering the location of housing, economic uses and community facilities and services. NPPF 100. It is important that a sufficient choice of early years, school and post-16 places are available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education. They should: a) give great weight to the need to create, expand or alter early years, schools and post-16 facilities through the preparation of plans and decisions on applications; and b) work with early years, school and post-16 promoters, delivery partners and statutory bodies to identify and resolve key planning issues before applications are submitted. NPPF 105. Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails. NPPF 109. Transport issues should be considered from the earliest stages of plan-making and development proposals, using a vision-led approach to identify transport solutions that deliver well-designed, sustainable and popular places. This should involve: a) making transport considerations an important part of early engagement with local communities; b) ensuring patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places; c) understanding and addressing the potential impacts of development on transport networks; d) realising opportunities from existing or proposed transport infrastructure, and changing transport technology and usage – for example in relation to the scale, location or density of development that can be accommodated; e) identifying and pursuing opportunities to promote walking, cycling and public transport use; and f) identifying, assessing and taking into account the environmental impacts of traffic and transport infrastructure – including appropriate opportunities for avoiding and mitigating any adverse effects, and for net environmental gains. NPPF 110. The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making. NPPF 124. Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land. NPPF 129. Planning policies and decisions should support development that makes efficient use of land, taking into account: a) the identified need for different types of housing and other forms of development, and the availability of land suitable for accommodating it; b) local market conditions and viability; c) the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use; d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and e) the importance of securing well-designed, attractive and healthy places. NPPF 132. Plans should, at the most appropriate level, set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics. Neighbourhood planning groups can play an important role in identifying the special qualities of each area and explaining how this should be reflected in development, both through their own plans and by engaging in the production of design policy, guidance and codes by local planning authorities and developers. NPPF 135. Planning policies and decisions should ensure that developments: a) will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development; b) are visually attractive as a result of good architecture, layout and appropriate and effective landscaping; 40 c) are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities); d) establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit; e) optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and f) create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users51; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience. NPPF 161. The planning system should support the transition to net zero by 2050 and take full account of all climate impacts including overheating, water scarcity, storm and flood risks and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure. NPPF 187. Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate; d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures and incorporating features which support priority or threatened species such as swifts, bats and hedgehogs; e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans; and f) remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. NPPF 189. Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas, and should be given great weight in National Parks and the Broads. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas. NPPF 192. To protect and enhance biodiversity and geodiversity, plans should: a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity. NPPF 198. Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. In doing so they should: a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life72; 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. NPPF 212. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm total loss or less than substantial harm to its significance. NPPF 213. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of: a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional; b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional. environment Decarbonisation of the transport sector should be promoted and implemented

NON-COMPLIANCE WITH COLCHESTER CITY COUNCIL’s TRANSPORT MODAL SHIFT IMPERATIVE The large draft Langham housing allocation runs totally counter to Colchester City Council’s well documented and self-acknowledged challenging modal shift imperative. Ambitious modal shift programs will be most effective in sustainable locations close to local services. In Langham, their effect will be marginal at best, as recognised in the October 2025 update to the Transport Evidence. As National Highways also state in their Oct 2023 Planning for the Future guide: “where developments are located, how they are designed and how well delivery and public transport services are integrated has a huge impact on people’s mode of transport for short journeys”. But not on longer journeys from remote rural locations such as Langham, one can safely infer. The large draft Langham housing allocation also runs counter to many other strategic policy documents referenced in Colchester City Council’s Transport Evidence. National Highways’ Planning for the Future Guide (Oct 2023) states that “NH will therefore expect those responsible for preparing local and neighbourhood plans to only promote development at locations that are or can be made sustainable and where opportunities to maximise walking, wheeling, cycling, public transport and shared travel have been identified.” The Transport East Transport Strategy (2023-2050) sets the following first two goals: Goal 1: Reduce demand for carbon intensive transport trips through local living by making it easier for people to access services locally or by digital means. Goal 2: Shift modes by supporting people to switch from private car to active travel, shared and passenger transport, and goods to more sustainable modes like rail. The Essex County Council Climate Action Plan outlines the Avoid Shift Improve approach: Avoiding unnecessary motor vehicle trips Encouraging residents to shift to sustainable modes such as walking, cycling and public transport Improving the efficiency and sustainability of essential journeys through initiatives focused on improving bus provision The Essex County Council Local Transport Plan, currently still being drafted for LTP4, aims that: People and goods can get where they need to go efficiently and sustainably Everyone should have good sustainable access to work, education and training, essential services and leisure activities, wherever in the county they live Investment should focus on ways to travel which protect and enhance the local enhance the local environment.

NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s CLIMATE AND NET-ZERO GOALS Designed-in car dependency will exacerbate carbon dioxide emissions The typical UK personal carbon dioxide budget currently comprises 22% from personal transport, and 14% from home electricity and heating (the remaining components being 29% good & services, 17% food, 7% aviation, and 11% other). Colchester City Council’s Feb 2025 Transport Evidence Report identifies Langham within one of Colchester’s two least sustainable MSOA(*) geographies (along with West Mersea). The Langham MSOA exhibits Colchester’s highest car transport mode share of 77.91% (compared with typical figures of 40-60% in the urban parts of Colchester). (*: MSOA = Middle Layer Super Output Area, a medium–sized statistical geography used in transport planning and socio-economic research). Building 910 new homes in Langham will likely add approaching 2,000 additional heavily used cars to the highest car-use MSOA (MSOA 001) in Colchester. Mitigation projects to encourage Active travel will be expensive (if funded) and largely ineffective The journey distances to Colchester Mainline Station (5.8 miles) and Manningtree Station (5.8 miles) are too great to encourage any modal shift to cycling, for rail commuters. The shorter 2.8 miles journey distance to the northern end of Rapid Transit System may encourage some limited modal shift for commuting into Colchester, but only with provision of a dedicated and expensive cycleway connection that avoids the perilous current rat run along Langham Lane. Such a åascheme is proposed within the infrastructure project schedule, with an indicative cost of £9m and indicative timing of 2034-37, but with no funding secured and it is hard to imagine that such a scheme will prove cost effective, functionally effective and therefore deliverable in these timescales. Any positive climate impacts of Net Zero homebuilding standards will be more than offset by negative climate impacts from increased road transport. Colchester City Council’s net-zero policies exhibit a clear imbalance between home and transport measures to reduce Carbon dioxide emissions. Policies NZ1 and NZ2 demand expensive net zero homebuilding standards on the grounds that Building Regulations 2021 and Future Homes Standard 2025 “do not adequately address operational or embodied carbon emissions from new development…it therefore falls to the planning system to ensure new development addresses carbon emissions in a way that aligns with local and national climate targets.” But there is no correspondingly high ambition to properly address the more significant personal transport based carbon emissions, which actually generate a substantially larger contribution to overall carbon budgets. Colchester City Council’s net-zero policies are therefore clearly not optimised to address local and national climate targets effectively. They should be fundamentally reviewed to seek a more balanced approach. Negative impacts will arise not only from the direct additional Langham traffic generation, but also increased emissions from extra congestion delays at the A12/A120 junction and the main Ipswich Road route into and out of Colchester (both of which will be heavily loaded by extra traffic emanating from a strategic Langham housing allocation). All of Colchester City Council’s Transport Modelling work is indicative of worsening congestion problems in many areas of the City, including the A12/A120 junction and the Ipswich Road, even with ambitious modal shift programs. More congestion and travel delays means more carbon emissions.

In relation to justification and lauding oof the proposed housing development near the Park and Ride I found on CCC website a quote from Cllr Julie Young “Too many families in Colchester are living in temporary accommodation or struggling to find a home that meets their needs. By bringing these plots to market, we’re taking a real step toward changing that. This is about using council-owned land to create homes that people can actually afford – homes that are close to jobs, schools, and transport links. Northern Gateway isn’t just a development site; it’s a chance to build a community where people feel secure, supported and connected to the rest of the city.” The proposal development for Langham is NOT CLOSE TO JOBS NOT CLOSE TO SCHOOLS NOT NEAR TO MEDICAL FACILITIES NOT NEAR TO TRANSPORT LINKS - Langham is at least 8 miles from the city centre and approximately 6 miles from the major commuting railway link. NOT CONNECTED TO THE CITY - FAR FROM IT -- Langham is at least 8 miles from the city centre and approximately 6 miles from the major commuting railway link. WILL NOT BUILD A COMMUNITY - it will be a suburban imposition and destroyer of a small village

LACK OF PLAN WITH FUNDING PROPOSALS TO DELIVER ESSENTIAL INFRASTRUCTURE UPGRADES In Langham there is a longstanding and well documented problem of overloaded sewage treatment works and sewer network. In September 2017, Colchester Borough Council, Anglian Water and the Environment Agency signed a Joint Position Statement following the publication of the December 2016 Water Cycle Study. This report recommended that new housing growth needed to be phased in line with infrastructure improvements to ensure that Langham WRC could provide the increased capacity required. In practice, no such infrastructure improvements have been implemented over the 8 years since then, and as a result the 80 Langham homes included in the current Local Plan have stalled with only 23 of the homes being built so far. Properties in Langham have suffered internal sewage flooding in 2016 and again in 2024, and three public meetings have been held in Langham between 2022 and 2024, with Anglian Water and our MP in attendance on each occasion. Our MP wrote to the CEO of Anglian Water in February 2024 requesting urgent remedial action, but to no avail. It has since become apparent (and has been confirmed in the new Water Cycle Study) that Anglian Water have no strategic investment plans for Langham WRC between now and 2050. There is NO credible and costed plan to deliver a legally compliant sewage treatment facility for any new homes, let alone over 1,100 homes (including the Boxted draft allocation of 150 and the unbuilt 57 homes from the current Local Plan) Anglian Water’s current Drainage and Wastewater Management Plan (published in May 2023 on a five yearly refresh cycle) confirms that there are no short medium, or long term upgrade plans for Langham WRC through the entire designated strategic planning timeframe right out to 2050. There is NO serious plans to resolve this showstopper identified anywhere within Colchester City Councils’ Evidence Base for the draft new Local Plan. Newmark’s strategic site viability assessment notes that “Extra sewage infrastructure will be required on site due to limited existing capacity; Anglian Water will require an onsite solution.” This statement is seriously ill-informed. The Environment Agency have confirmed in writing to Langham Parish Council that onsite sewage solutions are never permitted for developments of more than a handful of houses. This position is also clearly stated in the EA’s Foul Drainage assessment form FDA1. There is NO credible and costed plan to deliver essential local road safety upgrades to support road traffic growth. Colchester City Council’s infrastructure project schedule spreadsheet (Appendix A to the infrastructure audit and delivery plan stage 3 Report Updated) contains no identified highways upgrade projects associated with the strategic Langham site. This is a serious oversight. A number of significant upgrades will certainly be required, starting with the A12 northbound exit from the A12 into Park Lane. This is an unnumbered junction which involves a sharp turn of approximately 110 degrees into a narrow country lane (Park Lane), cutting across the exit lane from the Shell petrol station onto the northbound main A12 dual carriageway. This means that traffic exiting the A12 into Langham via Park Lane is already very dangerous as the same stretch of road that is used for decelerating traffic from the A12 competing with accelerating traffic from the petrol station and crossing each other. The 110 degree turn is already a highly dangerous junction, subject to at least two accidents in recent years, where cars leaving the A12 have failed to make the turn successfully and have crashed into the Langham property closest to the A12. We understand that a Starbucks is planned to be constructed at the petrol station site. This will substantially increase the volume of traffic involved in this dangerous manoeuvre further adding to the overall increase in traffic should this development proceed. As a result of these issues this junction will need a major re-design and be massively upgraded to improve road safety with the dramatic increase in local traffic entering Langham. Traffic entering the village from the southbound A12 carriageway turns immediately along Birchwood Road to a T junction Birchwood Road/Wick Road which is a small village junction with parked cars and vans restricting view in all directions. Which such a massive increase in population this would become a busy and inadequate junction. Upgrade will be needed, which is likely impossible due to houses positioned all around it. A more seriously dangerous junction is where the traffic from Birchwood Road/Wick Road turns right and meets the Wick Road/Park Lane junction. This junction is where the above mentioned traffic meets the traffic that has entered Park Lane from the A12 Northbound traffic that I have also already mentioned. This is already a dangerous junction where accidents have occurred previously. It is a very busy junction as traffic travelling north from Colchester up the A12 in the direction of Ipswich travel through Langham via Park Lane Park. It is a “rat run” especially at peak times. If the population of Langham is increased as suggested, and exiting on to Park Lane as planned, traffic on Park Lane will increase further, exacerbating the current position to the point of increased possibility of accidents, and potential traffic volume problems in the village. Speeding along Park Lane is also currently a serious problem. A major upgrade to this junction will be required at considerable cost. Park Lane, Moor Road and School Road currently have limited pavement provision, and traffic growth associated with 900 new homes will make pavement provision essential on these roads bordering the new development site. At the other end of the village there is likely to an issue at Park Lane/ Langham Lane as use of the junction substantially increases. As per other junctions in the village this is a small rural T junction not deigned to cope with the increased volumes that will ensue. This might also require an upgrade. It would be inappropriate of me to mention the infamous damaged Severalls Lane bridge over the A12, which has remained unrepaired for over six years now since the introduction of single lane operation under traffic light control? This road provides the primary local distributor road connecting Colchester with Langham and Boxted, and it will not be able to cope with the increased traffic from over 1100 new homes. Langham lane is constantly in need of repair at its perimeters. It is not designed to cope with its current volume and type of vehicles. There are no verges, no lighting, and multiple potholes. CCC promote greener travel, including bicycles. It is already very dangerous to cycle along Langham Lane to and from Colchester which renders cycling dangerous and not desirable at the present time, and it is highly unlikely that new residents would take that option with widening or general upgrade of the lane, which will lead to increased Langham/Colchester car traffic contrary to any green aspirations. There is NO credible and costed plan to manage projected increased on the A12 and Ipswich Road traffic congestion arising from this draft strategic site allocation. It is extremely unclear from the Transport and Further Transport Evidence reports whether or not the impact of 1100 new homes has been properly assessed in respect of congestion at A12 Junction 29 and the Ipswich Road leading into Colchester.

ENVIRONMENTAL DAMAGE There will be a loss of 40 hectares of prime Grade 2 agricultural land Colchester City council appears not to publish or track any statistics about agricultural land use shares and trends across its area, which is disappointing in the national context of monitoring trends in UK food production security (eg. The UK Food Security Index introduced by DEFRA in 2024). Severing of a recognised wildlife habitat corridor including rare bat species, nightingales and skylarks Roughly half of the proposed development site sits within various Strategic Opportunities areas designated in the Greater Essex Local Nature Recovery Strategy. Ecological surveys undertaken for recent small developments adjacent to the proposed large new development site have identified and observed 5 different bat species, nightingales, skylarks and badgers among other species. The mature hedgerows running through the site provide extensive habitat support, and whilst it is proposed to retain most or all of these hedges, the habitat disruption both during construction and afterwards (when the hedgerow habitats will have become fragmented and disconnected) will be severe. Increased effluent pollution damage to Black Brook and downstream River Stour . At a February 2024 public meeting in Langham (attended by our MP) Anglian Water formally confirmed that the Langham sewerage catchment area suffered from extreme levels of groundwater infiltration. The worst in their entire network in fact, barring a handful of low-lying catchments in the Norfolk Broads. As a result, wet weather periods lead to hydraulic overload causing sewage flooding incidents both in Langham village and at the WRC itself, where overflows pass directly into the Black Brook without going through all the treatment tanks. APPENDIX 6: LANGHAM WRC COMPLIANCE INSPECTION REPORT provides an example of this, in a report issued by the Environment Agency following a routine inspection visit in December 2023. The Black Brook water quality was tested in September 2025 as part of the Great UK Water Blitz citizen science program, at a location some 800m downstream of the WRC discharge point. The results showed very high levels of nitrate (5-10 mg/L) and phosphate (0.2-0.5mg/L) pollution. This is highly suggestive of human sewage pollution from the WRC (given that the upstream Black Brook does not sit close to many agricultural fields subject to fertiliser run-off). The Black Brook is a tributary of the River Stour, which it connects to in Dedham, very close to a water abstraction zone (SPZ1)

LANGHAM IS UNSUITABLE/UNSUSTAINABLE LOCATION FOR MAJOR HOUSING GROWTH The proposal is totally disproportionate to the existing community, infrastructure and amenities. Langham parish currently has 473 residential properties of which circa 350 are within the core village and the remaining 120-odd houses situated more remotely in the surrounding rural countryside. The proposed development would therefore increase the residential stock in Langham Moor and Wick from 350 houses to 1260 houses, representing a growth ratio of 360% in housing stock. The corresponding population growth ratio would almost certainly exceed 400%. The existing limited local village facilities will be totally overwhelmed by this level of population growth. These existing facilities (Community Centre, volunteer-run Community Shop, Pre-School, Recreation Ground and Children’s Play Area)) are all located along School Road outside the northern boundary of the proposed development. Any provision of alternative new more centrally located facilities would inevitably disrupt and threaten the ongoing viability of these current facilities. Comparing draft policies PP9 (North-East Colchester, 2,000 homes) and PP37 (Langham, 900 new homes) it becomes clear that there are no plans to build a new local centre in Langham, whereas in NE Colchester, policy PP9 para d) proposes “Provision of a new local centre to serve the new and existing local community, this may include provision of retail, commercial and community facilities at an appropriate scale, relevant to the role and function of a local centre and the communities it is intended to serve”. This absence of any suitable local centre in Langham will exacerbate the existing high car dependency within the village: for work commuting, school runs, shopping access, healthcare access and other services access. CCC’s February 2025 Transport Evidence Report recognises the following NPPF mandated key transport principles: PRIORITISING SUSTAINABLE MODES: The NPPF encourages planning decisions that prioritise walking, cycling, and public transport over car travel REDUCING RELIANCE ON CARS: Developments should be designed to minimise the need for car travel by locating them close to existing services, amenities, and transport infrastructure IMPROVING ACCESSIBILITY: New developments should be well-connected to public transport networks, cycle lanes, and pedestrian routes ADDRESSING TRAVEL DEMAND: Planning applications should assess the potential transport impacts of the development and propose measures to mitigate any negative effects Addressing Travel Demand: Planning applications should assess the potential transport impacts of the development and propose measures to mitigate any negative effects. The does not meet the test of any of the above principles. The development will not only impact Langham negatively; it will have an adverse effect on setting of adjacent Dedham Vale National Landscape where one third of the land area of Langham Parish sits within the Dedham Vale National Landscape, and the proposed site sits within 400m of the boundary on the eastern side, and within 800m of the boundary on the northern side. Another point on unsuitability is the Boxted airfield. The proposal is incompatible with NPPF (para 111f) requirement for Planning policies to recognise the importance of maintaining a national network of general aviation airfields in accordance with the Government’s General Aviation Strategy. Of interest is the work undertaken by Newmark for CCC that states as a site strength that “Minimal abnormal costs identified” and “National Highways have expressed no concerns”. Noting the many very real infrastructure issues this statement from Newmark strongly suggests a lack of due diligence in their strategic site assessment.