My objection essentially amounts to an objection to draft Policy PP37 for 900 homes on land north of Park Lane, Langham, which is considered to be a wholly inappropriate level of housing for the modest size of Langham village. The proposed housing allocation is contrary to national planning policy guidance set out in the NPPF, which is focused on planning for sustainable development. None of the related development plan ‘soundness’ tests would be met. The Draft Policy is also contrary to the Draft Local Plan’s Spatial Strategy which allows for limited housing growth in small and medium settlements appropriate to the size of the settlement and its constraints. The level of proposed housing at Langham, a medium settlement as defined in the Plan’s settlement hierarchy, is excessive and inappropriate. The initiative is ill conceived, unsustainable and unlikely to be deliverable due to a number of identified constraints and policy tensions.
LPC has had to focus a considerable amount of its limited resources into preparing its representations in response to the proposed strategic housing allocation. This is particularly disappointing given the absence of any meaningful engagement with the Colchester City Council (CCC) despite requests for meetings in an attempt to establish a suitable collaborative approach to planning for this part of the City Council area. I have legitimate concerns that the strategic housing allocation would introduce a car reliant housing estate, which would swamp my local community and do very little if anything to support it.
It is therefore, hoped that a more collaborative form of joint working can be established and that these representations will assist CCC in working with us towards securing a more suitable local planning policy.

My objection essentially amounts to an objection to draft Policy PP37 for 900 homes on land north of Park Lane, Langham, which is considered to be a wholly inappropriate level of housing for the modest size of Langham village. The proposed housing allocation is contrary to national planning policy guidance set out in the NPPF, which is focused on planning for sustainable development. None of the related development plan ‘soundness’ tests would be met. The Draft Policy is also contrary to the Draft Local Plan’s Spatial Strategy which allows for limited housing growth in small and medium settlements appropriate to the size of the settlement and its constraints. The level of proposed housing at Langham, a medium settlement as defined in the Plan’s settlement hierarchy, is excessive and inappropriate. The initiative is ill conceived, unsustainable and unlikely to be deliverable due to a number of identified constraints and policy tensions.
LPC has had to focus a considerable amount of its limited resources into preparing its representations in response to the proposed strategic housing allocation. This is particularly disappointing given the absence of any meaningful engagement with the Colchester City Council (CCC) despite requests for meetings in an attempt to establish a suitable collaborative approach to planning for this part of the City Council area. I have legitimate concerns that the strategic housing allocation would introduce a car reliant housing estate, which would swamp my local community and do very little if anything to support it.
It is therefore, hoped that a more collaborative form of joint working can be established and that these representations will assist CCC in working with us towards securing a more suitable local planning policy.

I object to Policy PP37 for Land north of Park Lane, Langham. The proposed allocation of approximately 900 dwellings is excessive for a rural settlement and risks fundamentally altering its character. The policy relies on future mitigation for highways, strategic road impacts, wastewater capacity, and environmental effects, none of which are guaranteed to be delivered in advance of development. Given existing pressures on infrastructure and the scale of growth proposed, this approach creates unacceptable risk for residents and the wider area. Development of this magnitude should not be allocated without firm, funded, and deliverable infrastructure solutions secured upfront.

Policy ST8 (Place Making Principles) Principles should “Protect the amenity of existing and future residents and users with regard to noise, vibration, smell, light pollution, loss of light, overshadowing and overlooking”. To date the CCC has failed to engage with LPC or attend LPC public meetings. There was no prior consultation with Langham residents before the announcement of this policy and minimal opportunity to engage with CCC since. ST7 provides ample opportunity for developers to apply for exceptions to policy compliance. The Langham proposals will fundamentally ignore the amenity of existing residents and is effectively a developers charter.

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.

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.

My objection essentially amounts to an objection to draft Policy PP37 for 900 homes on land north of Park Lane, Langham, which is considered to be a wholly inappropriate level of housing for the modest size of Langham village. The proposed housing allocation is contrary to national planning policy guidance set out in the NPPF, which is focused on planning for sustainable development. None of the related development plan ‘soundness’ tests would be met. The Draft Policy is also contrary to the Draft Local Plan’s Spatial Strategy which allows for limited housing growth in small and medium settlements appropriate to the size of the settlement and its constraints. The level of proposed housing at Langham, a medium settlement as defined in the Plan’s settlement hierarchy, is excessive and inappropriate. The initiative is ill conceived, unsustainable and unlikely to be deliverable due to a number of identified constraints and policy tensions. LPC has had to focus a considerable amount of its limited resources into preparing its representations in response to the proposed strategic housing allocation. This is particularly disappointing given the absence of any meaningful engagement with the Colchester City Council (CCC) despite requests for meetings in an attempt to establish a suitable collaborative approach to planning for this part of the City Council area. I have legitimate concerns that the strategic housing allocation would introduce a car reliant housing estate, which would swamp my local community and do very little if anything to support it. It is therefore, hoped that a more collaborative form of joint working can be established and that these representations will assist CCC in working with us towards securing a more suitable local planning policy.

My objection essentially amounts to an objection to draft Policy PP37 for 900 homes on land north of Park Lane, Langham, which is considered to be a wholly inappropriate level of housing for the modest size of Langham village. The proposed housing allocation is contrary to national planning policy guidance set out in the NPPF, which is focused on planning for sustainable development. None of the related development plan ‘soundness’ tests would be met. The Draft Policy is also contrary to the Draft Local Plan’s Spatial Strategy which allows for limited housing growth in small and medium settlements appropriate to the size of the settlement and its constraints. The level of proposed housing at Langham, a medium settlement as defined in the Plan’s settlement hierarchy, is excessive and inappropriate. The initiative is ill conceived, unsustainable and unlikely to be deliverable due to a number of identified constraints and policy tensions. LPC has had to focus a considerable amount of its limited resources into preparing its representations in response to the proposed strategic housing allocation. This is particularly disappointing given the absence of any meaningful engagement with the Colchester City Council (CCC) despite requests for meetings in an attempt to establish a suitable collaborative approach to planning for this part of the City Council area. I have legitimate concerns that the strategic housing allocation would introduce a car reliant housing estate, which would swamp my local community and do very little if anything to support it. It is therefore, hoped that a more collaborative form of joint working can be established and that these representations will assist CCC in working with us towards securing a more suitable local planning policy.

Scale of development is massively disproportionate.
Future housing demands of local residents does not justify such an increase.
Harm to village character and identity - not what residents chose when buying their homes in Langham.
Current infrastructure totally unsuitable for such a large development and no plan put forward to overcome this.
Local road network incapable of absorbing traffic increase from such growth (2000 extra cars?)
Limited public transport and limited local employment means long distance commuting likely.
Close proximity to the Dedham Vale National Landscape would have an adverse impact on the character of the area.

PP 37
Environmental damage.
It is a fact that the average water consumption per person per day in the UK is 140 - 150 litres. It is also a fact that the average people per household in the UK is 2.35 - 2.4 people, therefore, 900 properties would equate to 2,115 people. 2115 people x 140 litres equals 296,100 litres per day that needs to be treated and returned to the environment, I.e. the Black Brook tributary. This would compound the already high water table in the area. Adding to the already identified sewerage infrastructure problem of infiltration. This amount of effluent discharge will inevitably overwhelm his small river and lead to poor water quality as well as overwhelming the existing Langham Treatment Works making the matter worse. Any new private treatment plant proposed would fall into a Band 4 plant i.e. greater than 2000 population equivalent which would have a tighter Environment Agency permit applied. The consequences of this the works would have to higher standard than the current works.

There is no evidence in the plan of how the northbound slip road from the A12 to Langham will be addressed. This is already dangerous and accident prone, and once leaving the A12, Park Road is narrow and often cars need to pull to one side to allow for large lorries to pass as they join the A12 northbound. This could potentially cause tailbacks onto the A12 at a very dangerous spot on what is already one of the worst roads in the country.

Local roads are in a poor state of repair and ate not suitable for a sudden and massively increased number of vehicles accessing the roads.

The Park Lane / Wick Road junction is poorly designed and the Junction with Wick Road and Birchwood Lane would become something of a bottleneck. There does not appear to be any suggestion of who would make these changes.

This increased traffic which I estimate could be an additional 900 - 1500 journeys per day. This does not take into account the additional traffic created by servicing this increased population i.e, supermarket deliveries, trades, and other associated services.

Any large development contravenes Colchester Local Plan Policy DP17 (“Accessibility and Access”). Since the village is explicitly described as lacking suitable public transport.

Policy ST8 of the Colchester Local Plan outlines the "Place Shaping Principles" that guide how new developments should be designed to create high-quality, sustainable, and inclusive places. These principles ensure that growth enhances the character, functionality, and resilience of communities across Colchester.

A large development of 900 houses in Langham does not satisfy these criteria, it contradicts
them.
1. Langham is not close to the job market
2. There is a significant inadequacy with the provision of educational capability
3. Transport links are woefully inadequate to support such an expansion.
4. Langham is a rural village not connected to the rest of the city.
5. The are no established adequate routes that can support the increased traffic volume into
the city.
6. A development in the location proposed would effectively create two divided communities
unlikely to deliver a thriving, sustainable community.

The heart of the village currently consist of about 350 properties with a mix of single and two storey detached and semi-detached buildings, with approved planning permission for approximately 70 more properties. According to local housing surveys this meets the needs of the area for the next 15 years.

Looking at the size of the plot and with the already identified need for a Sewage treatment facility a very large attenuation lake and some green spaces the provision of 900+ homes estimate would be between an additional 1500 - 2000 vehicles needing to be parked with some capacity for visitor parking. The density of the development would need to be much higher than the existing properties and not in keeping with
he remainder of the village,
The current Primary School would not be able to accommodate the increased population, the village does not have any amenities poor public transport and no safe walking or cycle access and lack of facilities outlined below and would necessitate a huge increase in car journeys as it is near impossible to live in Langham without access to a vehicle, an example of this is, I personally know of one resident on Discovery Way who has moved into one of the affordable homes on the development. However, after having lived here less than a year she has had to purchase a car as public transport into Colchester using the local buses resulted in a 5 hour round trip. Every person on the estate has at least one vehicle.

in order to mitigate the need for journeys out of the village, Langham would require, a new primary school, the site of the current school would not allow for expansion. (as referenced in the IADP stage 3 report)
The preschool provisio
would also need significant expansion, as it is currently oversubscribed. The community facilities would be too small for the number of residents. The shopping facilities would require additional retail space. There currently is a lack of capacity for GP services in the area this additional number of residents would require a GP surgery.

The village is often subject to electricity power outages there were at least three in December 2025, the additional housing must put a significantly increased load on the current supply, and consideration would need to be taken for upgrading the supply.

This proposal would triple the size of Langham, fundamentally altering its historic settlement pattern and community balance. This level of growth is not justified by proportionate evidence and risks severe social, environmental, and infrastructure harm. Existing road capacity is already under significant stress during overlapping school peak periods, with unsafe congestion on School Road. Public transport is infrequent and unreliable, and local services are at capacity. The policy fails to demonstrate that surface water management, foul drainage, and wastewater discharge can be delivered without unacceptable risk to flood resilience and the local river. PP37 is therefore not justified or effective.

This proposes 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.

Contravenes Colchester Local Plan and NPPF, including:
Detrimental effect on local heritage of village - many Grade 2 listed buildings.
Too greater density of new housing for size of Langham- will destroy village.
Does not provide sufficient infrastructure for community and social requirements.
No local employment, schools, doctors, shops- more vehicles, more deliveries.
Access to village via A12 already dangerous with Shell garage and proposed Costa. Right hand turn from Severalls Road to Langham Lane narrow and blind. Major works required at both access points.
Proposed new sewage plant will produce water- no means for this to reach Black Brook.

The primary school is full and there is no secondary school in Langham. Therefore if 900 new dwellings are built, the children will all have to travel out of the village to school. Public transport is poor to the village and this would necessitate many more cars on the roads just to get them to school. Families will all require 2 cars which is completely non compliant with CCC's climate and net zero goals.
There is no street lighting in Langham and very few pavements. 900 additional households walking on the roads will be very dangerous.

According to CCC “Medium settlements include settlements with a range of community and social infrastructure but to a lesser extent than the infrastructure within the larger settlements. These medium settlements are capable of accommodating growth appropriate to the size, scale and infrastructure of the settlement.
Langham includes two areas of settlement, Langham Moor and St. Margaret's Cross, linked by School Road. A former WWII airfield lies between the two areas. The village contains a mixture of historic properties and farmhouses with more recent development. Langham contains a public house, a community café, a community shop, community centre, recreation ground, a playground, football pitches and tennis courts. It lies close to the A12 trunk road and the Dedham Vale National Landscape is outside the settlement to the north and east.”
The area according to CCC classifies Langham as a medium settlement, and describes the amenities, as a Public House (currently closed) Community shop (Run by volunteers) Community Cafe (Hosted once a month, 10 times a year by volunteers) it is a small community of approximately 350 homes surrounding the proposed development site. Which if it were to be approved would increase the population by more than 350% with little consideration for a planned growth of the community, this does not constitute an area “capable of accommodating growth appropriate to the size, scale and infrastructure of the settlement.” There are ongoing issues with the Sewage network with issues going back over a ten year period that Anglian Water themselves admit would cost at in excess of £10 million to address.
Langham appears to be targeted with a size of development completely disproportionate to the current settlement or in fact with any other medium sized settlement in the entire plan. Langham is a small village off the A12 accessed by a narrow accident prone slip road and a network of country lanes, with difficult junctions and poor footpaths and cycle or pedestrian access.
The rate of scaling necessary to achieve the integration of the increases in cars footfall residents is not reasonable or achievable in the life of the proposed plan. The area has poor public transport services and requires access to a vehicle, the senior school provision would require additional school bus services, the nearest School, The Gilberd is heavily oversubscribed, and the listed catchment school for Langham is St Helena in the middle of Colchester necessitating a huge increase in journeys.
With the need for so much infrastructure to be put in place, and the requirement for very high density housing, completely different to the current housing stock. The current approved housing developments are on hold due to the sewerage issues, which there is not any evidence of a resolution, it appears funds would need to be found for a private waste water treatment plant, significantly sized attenuation lakes, in excess of 10% of the land to designated open spaces, parking for a minimum of one vehicle per household. The lack of any evidence of funding to put the necessary services and infrastructure in place.
I question the financial viability to make this site attractive to potential developers, without significant compromises which would destroy the character of the village.

There is no evidence in the plan of how the northbound slip road from the A12 to Langham will be addressed. This is already dangerous and accident prone, and once leaving the A12, Park Road is narrow and often cars need to pull to one side to allow for large lorries to pass as they join the A12 northbound. This could potentially cause tailbacks onto the A12 at a very dangerous spot on what is already one of the worst roads in the country.

Local roads are in a poor state of repair and ate not suitable for a sudden and massively increased number of vehicles accessing the roads.

The Park Lane / Wick Road junction is poorly designed and the Junction with Wick Road and Birchwood Lane would become something of a bottleneck. There does not appear to be any suggestion of who would make these changes.

This increased traffic which I estimate could be an additional 900 - 1500 journeys per day. This does not take into account the additional traffic created by servicing this increased population i.e, supermarket deliveries, trades, and other associated services.

The sewage system in Langham is at breaking point! It is over capacity and has been for most of the last 10 years. There are regular issues where raw sewage leaks through broken pipes and floods into villager's gardens.
It is not possible to cope with the addition of 900 extra dwellings. Anglian Water have no plans for the next 25 years in improving the sewage system in Langham. The additional water created by these houses would require a large pipe to direct it to Black Brook and even then is way more than it can accommodate.

Road access to Langham is not good. The addition of 900 dwellings, with potentially 1800 more vehicles entering and leaving would make the roads much more dangerous. The junction from Severalls Lane into Langham Lane is narrow and a blind corner. The junction with the A12 and Park Lane is already hazardous with cars accelerating entering the A12 from the Shell garage as cars are slowing to exit the A12 to turn into Langham.
There are no plans to improve either of these roads so 1800 more cars would mean accidents waiting to happen.

Langham, a rural village of around 900 residents, has a history dating back nearly 1,000 years in the Domesday Book. Langham Airfield, a site of national significance, played a key role as an American airbase in World War II. While no longer fully operational, parts remain in use for light aviation and are preserved for their historic value. The proposed housing would directly threaten the airfield’s continued use, harm the village’s historic character, and introduce buildings into the flight path, creating serious safety risks. This development would erode Langham’s heritage and rural identity and is wholly inappropriate.

I strongly object to PP37, which would triple Langham’s size, fundamentally altering its historic settlement pattern and community balance. Such growth is disproportionate and unjustified, risking severe social, environmental, and infrastructure harm. Existing roads are heavily congested, especially during school peaks, with unsafe conditions on School Road. Public transport is infrequent, and local services are at capacity. The proposal fails to demonstrate that surface water, foul drainage, and wastewater can be managed without threatening flood resilience of the local river. PP37 is therefore neither justified nor effective, and approval would cause irreversible harm to Langham.

The proposed PP37 allocation would increase Langham’s size by over 250%, an expansion wholly disproportionate to its historic growth and settlement hierarchy. Such dramatic growth threatens community cohesion, erodes village identity, and undermines social sustainability. The policy provides no clear justification for why a rural village with limited services and employment opportunities should accommodate this scale of development. There is no evidence demonstrating that this level of growth is necessary or preferable to alternative locations. Without robust justification, PP37 is unsound and risks causing long-term harm to the social, cultural, and community fabric of Langham.

Policy PP37 fails to demonstrate that the local highway network can safely accommodate the cumulative impact of 900 new dwellings. School Road already suffers severe congestion and safety hazards during overlapping drop-off and pick-up times for Langham Primary School, Langham Preschool, and Oak School, endangering pedestrians, cyclists, and drivers. Public transport is infrequent, unreliable, and insufficient to reduce car dependency, meaning additional housing would worsen existing traffic pressures. The policy offers no robust evidence that proposed transport mitigation measures are deliverable or effective. Consequently, PP37 is unsound, failing the tests of effectiveness, safety, and consistency with sustainable transport objectives.

Policy PP37 does not demonstrate that surface water drainage, foul sewer capacity, and wastewater treatment can be delivered without unacceptable environmental risks. Existing infrastructure is already under significant pressure, and the policy provides no clear evidence of required upgrades, funding, or phased implementation. Without such measures, increased surface water runoff and treated effluent discharge are likely to compromise flood resilience and harm the local river environment. In the absence of a robust, funded, and deliverable water management strategy, Policy PP37 is inconsistent with national planning policy on flood risk, climate resilience, and protection of the natural environment.

The land north of Park Lane is classified as Grade 2 agricultural land, among the most productive and valuable in the region. Preserving it for farming is vital to support local food production, reduce dependence on imports, and strengthen national food security. In addition, this land provides important habitats for wildlife species, contributing to biodiversity and ecosystem health. Developing it would result in the irreversible loss of fertile soil, disrupt local ecosystems, and undermine efforts to maintain sustainable agriculture and environmental protection. For the long-term benefit of both people and wildlife, this land must remain in agricultural use.

Dear Sirs
Colchester City Council Local Plan Review – Regulation 18 Consultation
‘Soundness’ Representations concerning Draft Policy PP37: Land north of Park
Lane, Langham
Further to the above Local Plan Regulation 18 consultation, we write to provide our representations for
your consideration concerning objections to draft Policy PP37 which proposes 900 new homes at Langham.
We are Langham residents and have lived in the village for around 24 years. We are also chartered town
planners and run Lawson Planning Partnership, an award-winning consultancy based at Severalls Business
Park in Colchester, which has a focus on promoting and delivering sustainable development. Our
representations set out below are made in our capacity as local residents.
Summary
1. In summary, we consider that draft Local Plan Policy PP37, which is a strategic allocation for 900 homes,
does not represent sustainable development. It is a disproportionately large housing development
abutting Langham, a relatively small village with few facilities and very limited sustainable transport
opportunities to link with Colchester and other sustainable settlements.
2. The draft Policy is also at odds with NPPF guidance on planning for sustainable development and is
contrary to the draft Plan’s Themes and Objectives at Paragraph 2.21 and Spatial Strategy set out in
Policy ST3. This also requires the Plan’s related sustainability appraisal to be reassessed in this regard as
the Langham allocation has been incorrectly graded.
3. Notwithstanding the tensions with national and local planning policy, the housing allocation appears
speculative in nature, evidenced by the absence of any related land budget, surveys/studies and
delivery mechanisms normally provided by promoters at this stage in the planning policy process for a
strategic development of this nature and scale. Coupled with identified significant development
constraints including an infrastructure shortfall (existing and pipeline) and conflict with a private airfield,
this also indicates a lack of certainty over the deliverability of the site during the Plan period.
Place Strategy Manager -2- 13th January 2026
4. The absence of necessary infrastructure and mitigation including sustainable transport links and
wastewater drainage provision as identified in the related evidence based documents, also exposes the
vulnerable nature of this draft allocation from a sustainability and deliverability perspective.
5. The site is in productive agricultural use forming best and most versatile (BMV) agricultural land, with no
indication from the owners that the continued cultivation of this valuable arable land asset is likely to
cease.
6. These shortcomings indicate a lack of suitability, availability and deliverability associated with the draft
allocation, which would be inconsistent with the objective of contributing to the achievement of
sustainable development as required by para 16a) of the NPPF.
7. Additionally, there are consequential tensions with all four soundness tests set out in paragraph 36 of
the NPPF. It is therefore, requested that Policy PP37 is deleted from the draft Plan and replaced with an
appropriate alternative housing strategy focused on directing this significant strategic level of growth to
other more appropriate locations including the northern fringes of Colchester. Provision for a suitable
level of development for approximately 90 homes at Langham could also be made.
Representations
8. Our objections set out in these representations concern the inappropriate scale of housing development
proposed for Langham contained in draft Policy PP37 and lack of deliverability prospects during the Plan
period. We consider that 900 new homes attached to a village which has only 420 households, very
limited transport accessibility and community and employment facilities is simply too large and
excessive for this location. The Policy appears inconsistent with each of the draft Plan’s Themes and
Objectives at paragraph 2.21 and is contrary to the Plan’s own settlement hierarchy and Spatial Strategy
included in Policy ST3. This additionally requires the draft Plan’s sustainability appraisal to be
reassessed in respect of draft Policy PP37 as it indicates an unjustified bias in favour of sustainability
attributes, which are absent.
9. In this regard, the draft Plan at paragraph 3.23 states, ‘The settlement hierarchy identifies medium and
small settlements where growth is allocated appropriate to the size of the settlement and its constraints
(underlining our emphasis).’ Langham is defined as a Medium Settlement (fourth in the settlement
hierarchy) and yet has been allocated a significantly higher number of dwellings compared with each of
the ‘Large Settlements’ of Tiptree, West Mersea and Wivenhoe. There seems to be no planning
rationale which could justify this level of housing in this location.
10. Also, as identified within the Local Plan Evidence Base documents, the required infrastructure needed to
support this growth in Langham including sustainable transport provision and wastewater capacity is
not available and is unlikely to be delivered either. A strategic development of this size should also be
backed up by a range of related surveys and studies usually undertaken by the promoter to
demonstrate deliverability and made consistent with the LPA’s related sustainability assessment to
warrant support and justification as a Local Plan allocation.
11. However, other than a broad layout plan provided by a land agent, which has not taken account of key
development constraints, the draft allocation appears as a line on a plan isolated from a sustainable
settlement. It represents the type of residential development that was prevalent in the 1960’s and
Place Strategy Manager -3- 13th January 2026
1970’s, which experienced significant housing growth in rural areas, resulting in car reliant satellite
dormitories.
12. Yet, the current policy emphasis on settlement planning requires significant growth to be focussed at
locations which are or can be made sustainable, through limiting the need to travel and offering a
genuine choice of transport modes (NPPF paragraph 110). Despite the long list of requirements set out
in draft Policy PP37, there is no evidence to show how the required infrastructure would be provided
and sustainable development achieved. The development of 900 homes at Langham could result in
1,000 to 1,500+ AM and PM peak car borne trips, with little mitigation identified, offered or achievable
to bring about a suitable modal shift in favour of sustainable transport modes. Utilising the strategic
road network via the A12 Trunk Road for localised car based trips is inappropriate. Also, the local route
to Colchester via Langham Lane, a well used ‘rat-run’ to and from the A12 and Colchester, is inadequate
for the type of utilisation involved and could not reasonably accommodate cycle lanes.
13. Irrespective of the sustainability deficiencies of the proposed 900 homes, the Local Planning Authority
(LPA) is also expected to demonstrate that there is a reasonable prospect that proposed development
can be developed within the timescale envisaged, which appears to be absent.
14. A further key constraint in this regard, is the absence of existing and future wastewater capacity
identified in the WRC study evidence document, probably necessitating the need for an on-site sewage
treatment plant and associated cordon sanitaire, which could extend beyond 200 metres for a facility
capable of dealing the level of effluent generated by 900 homes.
15. Also, the need for a no-development airfield safeguarding zone at the western part of the site, north of
the existing airfield runway has not been included. The flight path of the airfield and low flying aircraft
are material considerations which do not seem to have been assessed. It is noted that reflector disks
were added to the overhead cables at the end of the runway on Park Lane as a hazard warning to pilots.
Consequently, an obstacle clearance zone on the western side of the site, kept clear of housing and
other built structures needs to be factored in as evidenced by our own experience of aircraft
approaching the airfield over existing housing located on School Road.
16. All of these constraints, which do not appear to have been assessed would significantly reduce the
housing capacity of the site, leading to a knock-on overall shortfall.
17. The site is currently in active agricultural use forming BMV land, providing arable crops on an annual
basis. The landowners have not to our knowledge expressed intentions to cease cultivating this
significant arable land resource, which should be retained for this purpose. There are plenty of
alternative green field sites, which are not actively cultivated, and the LPA’s housing land and site
assessment needs to be revisited with this important consideration in mind, as part of a sequential site
selection exercise.
18. Significant housing development of this scale needs to be accommodated within or adjacent to a larger
and sustainable settlement. There is no Green Belt around Colchester City and there are a range of sites
located on the northern fringes of the built-up area, which could be considered for further strategic
housing growth as an alternative. Although such development would breach the boundary provided by
the A12, it would allow new homes to be well linked to and integrated with the existing urban fabric
where there are good links to shops, services and employment opportunities via viable and convenient
bus (including park & ride & rapid transit), cycle and pedestrian routes and other infrastructure.
Place Strategy Manager -4- 13th January 2026
19. Therefore, there is no need to ‘leapfrog’ the urban fringe and push significant housing growth out to
Langham, which if it actually came forward, would do little more than create a large car reliant
dormitory settlement adjacent to the village.
20. Langham has relatively few community facilities and employment opportunities, although they provide
for the current village population, with some capacity to accommodate the identified level of housing
need set out in the Parish Council’s Housing Needs Study (2025). However, to have any chance of
achieving some form of self-sufficiency and a suitable homes – jobs alignment ratio, it is considered that
900 additional households would need to be supported by a much greater level of community,
employment and transport facilities, currently not planned for, creating a new settlement abutting the
village with little identified benefit to the existing community. If the achievement of sustainable
development is the key driver here, which it should be, there needs to be a radical rethink over locating
strategic levels of housing at Langham.
Conclusion
21. The proposed 900 home strategic allocation in draft Policy PP37 amounts to an unsustainable form and
pattern of development contrary to the planning policy principles for achieving sustainable
development set out in paragraph 11 of the NPPF and the emerging Local Plan strategy itself. The draft
allocation also raises identified deliverability issues and conflict with the soundness tests set out in
paragraph 36 of the NPPF as summarised below:
 Not positively prepared – the isolated strategic housing allocation at Langham would not contribute
to meeting the area’s objectively assessed needs consistent with achieving sustainable
development.
 Unjustified – attempting to locate 900 homes against Langham village is not an appropriate
strategy, especially when there are more suitable housing site options at sustainable locations.
 Ineffective – the identified constraints associated with the draft allocation and lack of any serious
development intentions and infrastructure investment, renders Policy PP37 an undeliverable option
for the plan period.
 Inconsistent with national policy – the 900 home allocation at Langham would not enable the
delivery of sustainable development in accordance with the policies of the NPPF and other relevant
national policies aimed at achieving sustainable development and combating climate change.
22. Therefore, it is requested that draft Policy PP37 is deleted from the draft Plan and replaced with an
appropriate alternative housing strategy focused on directing this high level of growth to sustainable
locations including the northern fringes of Colchester. Allowance for a modest level of housing growth
amounting to approximately 90 dwellings in line with the size of Langham and the identified level of
local need could be accommodated on other sites within the village.
23. Finally, although the Regulation 18 draft Local Plan represents the LPA’s ‘preferred options’ we
understand that officers are amenable to considering and pursuing suitable changes, where justified.
Similarly, it is also understood that the Local Plan Committee when resolving to approve the draft Plan
for consultation purposes at its November 2025 meeting, made clear that it was not approving or
Place Strategy Manager -5- 13th January 2026
supporting its content and therefore, it is assumed that the Committee will also be amenable to
considering and incorporating suitable changes too as included in our representations.
We hope you will find our representations to be helpful as part of the Local Plan preparation process and
that they will be taken into account by the Council’s Planning Policy Team and Local Plan Committee in due
course.

Contravenes Colchester Local Plan and NPPF
1. Contravenes Colchester Policy on Heritage / Environment.Contravenes stated green policies, increasing traffic/car use. Policy protects Langham as avillage, 900 additional houses would destroy the village as community.
2. Previously Colchester have refused planning as being detrimnetal to area/environment.
3. Contravenes Policy on Community and Social Infrastructure. Local amenities already overloaded. lack of schooling, GP surgeries, village amenities, and access to employment.
4. No safe access to village. From Colchester A12 Shell garage exit conflicts with access to village. Accident black spot. New Costa will exacerbate this. Blind junction Severalls/Langham Lane. Fatal accidents potential.