CCC - Heritage Impact Site Assessment - February 2025 - Langham
Wick Road (site PP38) should be given the same level of heritage assessment as PP37. It is immediately adjacent to PP37 and warrants the
Proforma, high impact assessment as well as PP37 rather than the lower classification suggested in the site assessment.

as previous

OBJECTION - Highways, Traffic, and Rural Lanes
I object to PP37 and PP38 on highways grounds. Langham is served by narrow, rural roads such as School, Wick, Moor, and Park Lane which are not capable of safely accommodating the additional traffic generated by a 900-dwelling development. There is no evidence in the Draft Local Plan demonstrating that appropriate junction improvements, pedestrian provision, or traffic management can be delivered without undermining the rural character of these lanes. The scale of traffic increase would also compromise road safety for all. The proposed allocation is therefore unsustainable and unsound.

OBJECTION - Highways, Traffic, and Rural Lanes
I object to PP37 and PP38 on highways grounds. Langham is served by narrow, rural roads such as School, Wick, Moor, and Park Lane which are not capable of safely accommodating the additional traffic generated by a 900-dwelling development. There is no evidence in the Draft Local Plan demonstrating that appropriate junction improvements, pedestrian provision, or traffic management can be delivered without undermining the rural character of these lanes. The scale of traffic increase would also compromise road safety for all. The proposed allocation is therefore unsustainable and unsound.

These sites are located in close proximity to numerous Grade II listed buildings
Initial assessment
While development could be acceptable, a full Heritage Impact Assessment will be needed to confirm the site’s suitability from a historic environment perspective and to identify appropriate mitigation measures or opportunities for enhancement. The resulting recommendations should then be incorporated into criteria ‘m’ and ‘j’ of the corresponding policies.

I support the principle of small scale housing in Langham where it is proportionate and sensitively designed. However, the policy relies heavily on future agreements and demonstrations, particularly around highway safety, pedestrian connectivity and wastewater capacity. Clearer assurance is needed that safe pedestrian access can be delivered without harming rural character, and that Anglian Water capacity is genuinely available at the point of connection. Phasing triggers and mitigation measures should be clearly defined to ensure infrastructure keeps pace with development and does not place additional pressure on existing residents or services.

Already very busy with traffic. Nasty junction. Accident hotspot. Traffic leaving A12 & going too fast towards that junction. Overwhelmed & ancient sewerage system. Loss of rural identity

I object to the scale of the proposed housing development in our rural village. We have already accepted recent development, but this new proposal would more than double the size of the village, fundamentally changing its character. Residents paid a premium to live here because it is quiet, rural and peaceful, and that will be lost. Wick Road will face a vast increase in traffic, yet the infrastructure is not capable of supporting it. This level of development will significantly harm quality of life, creating congestion, noise and disruption. It is unfair and will likely devalue existing homes, forcing some residents to consider leaving

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.

The current sewage and surface water situation does note cope with the current requirements of the village. Constant flooding and sewage spillage and break in freshwater pipes. The system is crumbling and overloaded.
Roads are crumbling and dangerous as inadequate speeding restrictions enforced. Loss of rural habitat

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.

Strong indication to include equestrians due to the semi-rural and rural location of this site. Ensure provision of green infrastructure connections and recreational access to the countryside that includes equestrians. Horses stabled and ridden out at Langham. Close to Bridleway 20 Langham and Bridleway 40 Langham. Infrastructure must be designed as multi-user routes (MURs) to ensure inclusivity for all non-motorised users, at a minimum, to Bridleway status. MURs function as public highways and are best defined as restricted byways—open to pedestrians, horse riders, cyclists, and users of non-motorised vehicles—or as bridleways, which permit access for pedestrians, horse riders, and cyclists.

10 dwellings seems a reasonable and acceptable amount to add to the area, provided the sewerage is able to take the additional load.

I am writing to confirm my formal objection to the development proposal for the 900 properties at Langham, Colchester.

I am a resident on Wick Road, Langham.

My reasons for the objection are as follows:-

The development is clearly out of proportion to the size of the village. Presently there are approximately 300 homes in the core of the village. Adding 900 to this is clearly ridiculous and will destroy the essence of a village. This is the equivalent of adding 240,000 to Colchester. I am aware that there is a need to meet targets but CCC has obviously panicked and thrown a balancing number at a field with an adjacent road access.

The infrastructure is only just adequate for the existing properties namely:-
Frequent pipe bursts
Sewage flooding due to overloaded treatment works
Frequent power cuts
Poorly maintained footpaths and roads
No street lighting
Dangerous access off the A12

CCC has insufficient funds to undertake their elements of the above works and the highway authority and utility providers have no interest in upgrading their infrastructure.

This is cruel way to treat people who have chose to live in a village rather than a town or city.

I completely endorse and support the reasons for objection raised by Langham Parish Council and request that the proposal is withdrawn.

Regards,

Phil

Philip Williams

In the current housing climate (not much is selling as my next door neighbour recently removed his house from sale due to lack of interest opposite Wick Rd),how do 10 new homes meet 'Evidenced needs' ??
This along with 900 homes planned in the field adjacent are also 'Evidenced needs'....by whom ??
These homes are obviously being proposed due to the A12 being very close by for transport reasons
An extremely busy road now which is why there were plans to widen it and has now been cancelled by the present government !

.

Colchester City Council Local Plan Review: Langham Parish Council Response to Regulation 18 Local Plan Consultation
We write to set out Langham Parish Council’s (LPC’s) representations on the Regulation 18 draft Local Plan for your consideration.
Executive Summary
Langham Parish Council objects to the allocation of 900–910 homes at Land North of Park Lane (Policies PP37 and PP38) on the grounds that it fails all four soundness tests required by NPPF paragraph 36. The allocation is not positively prepared, not justified, not effective, and not consistent with national policy.
Not Positively Prepared. The allocation proposes 910 homes in a village of 473 existing addresses, representing 192% growth. Langham comprises 0.5% of Colchester’s population but receives 5% of housing growth—32 times more development per existing household than Large Settlements combined (1.92 vs. 0.06). This extreme disproportionality violates the Settlement Hierarchy (Policy ST3), which designates Langham as a Medium Settlement yet allocates it almost as much growth (910) as the three Large Settlements combined (1,120). Langham Parish Council’s commissioned Housing Needs Assessment identifies genuine local need of 60–120 homes; the 910-home allocation therefore fails to address the objectively assessed need for housing in this area.
Not Justified. Langham scores 34 on the DfT Connectivity Tool, making it less sustainable than other Medium Settlement allocations. Comparators with superior connectivity receive substantially lower allocations: Copford (300 homes, score 55), Eight Ash Green (430, score 49), West Bergholt (250, score 48). The emerging NPPF requires use of the Connectivity Tool (policy TR1). The Council has failed to justify why Langham represents an appropriate strategy compared to better-connected alternatives. The allocation contradicts the Council’s own Transport Evidence (identifying Langham’s MSOA as having highest car dependency at 77.91%) and Landscape Character Assessment (stating “visually intrusive development should be avoided” near Dedham Vale). Site assessment inconsistencies further undermine justification: Boxted site 10685 was rejected for being disproportionate to village scale despite that site being 67% of size of the Park Lane site and Boxted having 50% greater population.
Not Effective. The allocation is undeliverable due to fundamental infrastructure constraints with no secured solutions. Langham WRC operates beyond capacity and would reach 125% over-capacity if the allocations were built out (Water Cycle Study, October 2025). Anglian Water’s DWMP contains no upgrade plans to 2050, and no funding mechanism exists for strategic infrastructure contributions. The 2017 Joint Position Statement (CBC, Anglian Water, Environment Agency) recommended phasing growth with infrastructure improvements; eight years later, zero improvements have been delivered and only 23 of 80 allocated homes have been built. Newmark’s suggestion of “onsite solutions” is legally impermissible per Environment Agency guidance (FDA1). Langham Primary School operates at 95% capacity with no expansion potential. The Infrastructure Project Schedule identifies no highway upgrades despite critical safety deficiencies at the A12 junction (110-degree turn across filling station exit with <100m spacing, below DMRB standards). The proposed £9.7m Langham Cycle Route & Mobility Hub (2034–37) (Project IDs 137 & 163) has no secured funding. Without secured infrastructure delivery, the allocation fails NPPF paragraphs 35 and 77.
Not Consistent with National Policy. The allocation violates NPPF 77 (requiring large-scale development to be “well located” with “genuine choice of transport modes”), NPPF 110 (requiring focus on “sustainable” locations “limiting the need to travel”), and NPPF 161 (requiring support for net zero transition through “radical reductions in greenhouse gas emissions”). Langham has the highest car dependency in Colchester; no local centre is proposed (unlike NE Colchester’s 2,000-home allocation); and the development will add ~2,000 cars, directly undermining climate policy. The allocation violates NPPF 189 (requiring development within National Landscape settings to “avoid or minimise adverse impacts”), section 245 of the Levelling-up and Regeneration Act 2023 (duty regarding Protected Landscapes), and NPPF 212–213 (requiring “great weight” to heritage conservation and “clear and convincing justification” for harm). The allocation destroys 40ha of Grade 2 agricultural land (NPPF 187(b)) and severs wildlife corridors within the Greater Essex Local Nature Recovery Strategy areas (NPPF 192), with five bat species, nightingales, and skylarks identified.
Breach of Habitats Regulations. The HRA fails to comply with the Conservation of Habitats and Species Regulations 2017. While correctly identifying likely significant effects on the Stour and Orwell Estuaries SPA, the Appropriate Assessment fails to demonstrate beyond reasonable scientific doubt that adverse effects on site integrity (AEoSI) will be avoided. The AA improperly relies on unsecured mitigation (Anglian Water has no investment plans to 2050), substituting planning conditions for secured mitigation contrary to Natural England guidance and the precautionary principle. The HRA fails to assess on-site wastewater treatment impacts. Black Brook water quality testing (September 2025) shows very high nitrate (5–10 mg/L) and phosphate (0.2–0.5 mg/L) pollution. The EA’s December 2023 compliance inspection documented sewage overflows bypassing treatment during wet weather. Without secured mitigation, AEoSI cannot be ruled out.
Conflict with Local Plan Policies. The allocation violates Policy ST8 (failing place shaping principles on character, heritage, public transport, car reliance), Policy LC1 (failing to safeguard landscape character, tranquillity, rural openness), Policy GN6 (destroying heavily used rural footpath network providing amenity and active travel), and Climate Policies NZ1/NZ2 (exhibiting imbalance between home and transport carbon measures—demanding net zero homebuilding while allocating 910 homes in the highest car-dependency location).
Conclusion. Policies PP37 and PP38 fail comprehensively to meet the legal tests required for a sound Local Plan. The allocation imposes extreme disproportionate growth unrelated to local need, represents an inappropriate strategy contradicting the Council’s own evidence, lacks secured infrastructure solutions, violates multiple NPPF requirements, breaches the Habitats Regulations through reliance on unsecured mitigation, and systematically conflicts with the Council’s own spatial strategy, settlement hierarchy, landscape, heritage, and climate policies. These cumulative failures render the allocation legally unsound. Langham Parish Council submits that Policies PP37 and PP38 must be deleted from the Regulation 19 submission to ensure the Local Plan can withstand examination. This response is supported by detailed evidence in Twelve Appendices.

Note 1: unless otherwise stated, all references to the National Planning Policy Framework refer to the December 2024 version which is likely to be the version still in force when the Planning Inspectorate review the Local Plan.
Note 2: thanks are due to all of the nine Langham900 Working Group members for their background research and contributions to this document.
Objection Category Headings
Our objections to Policy PP37 are focussed and structured under the following sub-headings.
1. Unsuitable/unsustainable location for major housing growth
2. Poor transport connections and lack of sustainable transport choice/potential
3. Environmental harms
4. Failure to comply with Habitats Regulations
5. Harms to existing community, heritage, National Landscape
6. Aviation and public safety considerations
7. Lack of plan with funding proposals to deliver essential infrastructure upgrades
8. Lack of plan with funding proposals to deliver essential local community amenities
9. Non-compliances with CCC’s Settlement Hierarchy (Policy ST3)
10. Non-compliances with CCC’s Place Shaping Principles (Policy ST8)
11. Non-compliances with CCC’s Landscape (LC1) and Retention of Open Space (GN6) Policies
12. Non-compliance with CCC’s Climate and Net Zero goals
13. Non-compliance with CCC’s transport modal shift imperative
14. Non-compliances with NPPF and emerging draft NPPF
15. Non-deliverability
16. Planmaking process weaknesses and discrepancies
17. Extreme mismatch with Local Housing Need
18. Site commercial viability doubts
Objection Details:
1: UNSUITABLE/UNSUSTAINABLE LOCATION FOR MAJOR HOUSING GROWTH
1.1 Totally disproportionate to existing community, infrastructure and amenities
According to the AddressBase dataset made available by the Ordnance Survey, Langham Parish has 473 residential addresses. (This is more reliable than the 555 figure from the 2021 Census, which relates to a Lower Layer Super Output Area that also includes part of Dedham and Ardleigh Parishes).
Of these 473 residential addresses, roughly 350 are situated in Langham Moor and Langham Wick, with the remaining 120-odd houses situated more remotely in the surrounding rural countryside.
The proposed development in the agricultural fields north of Park Lane, between Langham Moor and Langham Wick, would therefore increase the residential stock in the main settlement of Langham village 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%, noting the low current average occupancy ratios in the village (see APPENDIX 1: HOUSING NEEDS ASSESSMENT for further details on current occupancy ratios).
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. They are neither suitably situated nor scalable to support this dramatic population growth.
Any provision of alternative new more centrally located facilities, even if supported by the development (which is not currently proposed) would inevitably disrupt and threaten the ongoing viability of these current facilities. These facilities would need to be included within the development and would effectively create a new settlement adjacent to the village. It is likely that the development would neither complement nor integrate with the village from a physical, social or economic perspective and would represent poor place shaping in an unsustainable manner.
1.2 Substantial increase in car dependency
Comparing draft policies PP9 (North-East Colchester, 2,000 new homes) and PP37 (Langham, 900 new homes) it becomes clear that there are no plans to build a new local centre in Langham to support the extensive new development. By contrast, 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”. Even if such a facility was put forward it would do little to offset the high car dependency of this location with between 1,000 and 1,800 car based daily AM and PM peak time trips alone being generated.
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. Car use for the MSOA in which Langham is located is the highest in Colchester, making up 77.91% of journeys. Again, even if there was available highway capacity to accommodate these trips, it flies in the face of sustainable transport planning which is predicated on focussing significant development on locations which are or can be made sustainable through limiting the need to travel and offering a genuine choice of transport modes. This cannot realistically be achieved at Langham as evidenced by CCC’s background reports referred to below and a 900 home development would simply be a departure from recognised transport planning objectives, for which there is no justification.
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 (para 109.e)
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 (para 77)
Improving Accessibility: New developments should be well-connected to public transport networks, cycle lanes, and pedestrian routes (para 110)
Addressing Travel Demand: Planning applications should assess the potential transport impacts of the development and propose measures to mitigate any negative effects (para 109.f)
The February 2025 Transport Evidence Report aspired to deliver a 40% modal transport shift from car use to active travel modes for preferred site allocations. The October 2025 Further Transport Evidence Report assessed a wider evidence base and re-evaluated the modal transport shift down to a somewhat more plausible 22% for urban sites and 6-9% for rural sites. However, given Langham’s remoteness from Colchester’s facilities, even this 6-9% shift seems highly ambitious. It will certainly require a significant and well targeted program of investment coupled with effective marketing and education, if it is to be achieved in reality and not just in an aspirational transport model. Significant service launch delays and cost overruns in CCC’s flagship urban Rapid Transit System do not inspire confidence that enhanced public transport infrastructure can realistically be extended to remote rural areas in the timescales necessary to make a large Langham housing allocation sustainable.
1.3 No realistic infrastructure investment plan to make the site sustainable
The strategic site assessment for Langham, undertaken by Newmark for CCC, states as a site Strength that “Minimal abnormal costs identified” and “National Highways have expressed no concerns”. The safety implications of a significant increase in traffic utilising the Langham/Ardleigh junction from the northbound carriageway of the A12 do not appear to have been considered, despite the spacing between the on-slip from the Shell garage and the off-slip for the junction being less than 100m and significantly below current DMRB requirements. Noting the many very real infrastructure issues documented elsewhere in this report, these statements from Newmark strongly suggest a lack of due diligence in their strategic site assessment, and there is a real potential for the development to have an unacceptable impact on highway safety in this location contrary to NPPF para 116.

2: POOR TRANSPORT CONNECTIONS AND LACK OF SUSTAINABLE TRANSPORT CHOICE/POTENTIAL
There are few less suitable locations for 910 new homes across the Colchester area, if sustainable transport options are a serious consideration, which they need to be as explained in Section 1.2 above under the car dependency section. Whilst Langham does benefit from close proximity to the A12, its remoteness from other services and facilities more than outweighs this. To assess this more scientifically, the Department for Transport has developed a Connectivity Metric and Tool which evaluates the value of travel destinations and the opportunity to reach said destinations using various modes of transport, including walking, cycling, driving and public transport. It considers different purposes of travel, including employment, education, shopping, leisure and healthcare. Notably, the emerging draft NPPF requires the use of this tool to inform the assessment and selection of sites, in order that development will support sustainable patterns of movement and make effective use of existing or proposed transport infrastructure (draft NPPF para TR1:1.b)
The location of the land north of Park Lane in policy PP37 scores around 34 on the Tool. By comparison, other Medium Settlements identified for significantly smaller allocations benefit from higher connectivity scores:
a) Copford – Connectivity Score 55, Proposed Allocation 300 properties
b) Eight Ash Green – Connectivity Score 49, Proposed Allocation 430 properties
c) Layer de la Haye – Connectivity Score 41, Proposed Allocation 70 properties
d) West Bergholt – Connectivity Score 48, Proposed Allocation 250 properties
e) Rowhedge – Connectivity Score 44, Proposed Allocation 50
The draft NPPF (published December 2025 and currently in consultation) requires the use of DfT’s Connectivity Tool (policy TR1) to inform the assessment and selection of sites for development, reflecting the principles in Policy TR3. Although the emerging NPPF has not yet been adopted, the Secretary of State for Housing wrote to all Local Authority Leaders on 16th December 2025 providing guidance (amongst other matters) on the steps he was taking to ensure immediate application of the new NPPF policies as soon as they are published. A local plan approved under an earlier NPPF that is not consistent with the policies in the emerging NPPF (once adopted) will be given very little weight. It follows that CCC should be ensuring that the policies in its draft Local Plan are consistent with this emerging policy to ensure that the Local Plan is robust.
The justification for Policy PP37 relies heavily on good connectivity via the A12; however by utilising the Connectivity Tool as required by the draft NPPF, it becomes clear that proximity to the A12 is a poor substitute for proper connectivity between Langham and other areas. The mitigation proposed as Project IDs 137 and 163, together with improved bus services, would start to address the true shortfall in connectivity, but without funding for these being secured in advance of occupation of these properties, connectivity of the allocation in Policy PP37 falls far short of the requirements of draft NPPF Policy TR3.
Further details of the current state of public transport facilities in Langham are explained in APPENDIX 5: LANGHAM PUBLIC TRANSPORT REPORT.

3: ENVIRONMENTAL HARMS
3.1 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). The land is fully utilised for arable crops and there is no indication that this is to cease. There are plenty of options for developing other land, which has been withdrawn from productive agricultural use, which should take priority over the arable land north of Park Lane.
3.2 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. Skylark rely on open land for nesting, all of which will be lost to the development.
No justification is provided for the sacrifice of this environmental resource and no suitable mitigation is proposed. Leaving all these considerations to the planning stage is not appropriate, as there is no certainty over the deliverability of any meaningful biodiversity enhancements with this level of housing proposed.
3.3 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 very little of the upstream Black Brook sits adjacent to actively cultivated agricultural fields that could be 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), as shown in the map below:


4: FAILURE TO COMPLY WITH HABITATS REGULATIONS
The Council’s Habitats Regulation Assessment (HRA) of Local Plan Policy PP37 is legally and scientifically flawed and does not comply with the Conservation of Habitats and Species Regulations 2017. While the screening stage correctly identifies that development at Langham is likely to have a significant effect on the Stour and Orwell Estuaries SPA due to hydraulic connectivity with Langham Water Recycling Centre (WRC), the subsequent Appropriate Assessment (AA) fails to demonstrate, beyond reasonable scientific doubt, that adverse effects on site integrity (AEoSI) will be avoided.
The AA relies on the Water Cycle Study, which acknowledges that Langham WRC is already operating beyond capacity and would reach 125% over-capacity if the allocation proceeds without major infrastructure upgrades. Although upgrades are described as technically achievable, no funding, delivery mechanism, or timetable exists, and no investment is planned by Anglian Water to 2050. The AA improperly relies on a planning condition as a substitute for secured mitigation, contrary to Natural England guidance and the precautionary principle.
Furthermore, the HRA fails to assess the potential impacts of on-site wastewater treatment, which could itself affect protected watercourses. As mitigation is neither secured nor reliable, AEoSI cannot be ruled out. The conclusion of no harm is therefore unsafe.
Policy PP37 fails the tests of soundness, is undeliverable, and cannot meet the strict requirements of Regulation 107. It must be removed from the Local Plan. APPENDIX 9: LANGHAM SEWERAGE AND DRAINAGE REPORT provides further details.

5: HARMS TO EXISTING COMMUNITY, HERITAGE AND NATIONAL LANDSCAPE
5.1 Disproportionate growth does not allow for the existing community to evolve, adapt and integrate. It will instead be disrupted and largely destroyed
APPENDIX 7: LANGHAM LOCAL SERVICES REPORT provides a more detailed analysis of some of the likely impacts if the proposed development is allowed to go ahead, both through being incapable of providing support that new development needs and through overwhelming the limited existing provision.
5.2 The village’s long history, heritage and character will be overwhelmed and lost
APPENDIX 8: LANDSCAPE AND HERITAGE REPORT provides a more detailed analysis of the likely impacts if the proposed development is allowed to go ahead.
5.3 Damage to setting of Dedham Vale National Landscape
The northern entrance to the proposed development site directly abuts the Stour Valley Project Area and is within the setting of the Dedham Vale National Landscape, to which harm could be caused in contravention of the duty for CCC to seek to further the statutory purposes of Protected Landscapes (section 245 of the Levelling-up and Regeneration Act 2023).
This location sits at the boundary of the A7 (Stour River Valley Slopes) and B7 (Langham Farmland Plateau) Landscape Character Areas (LCA) described in the Colchester Landscape Character Assessment Report prepared as part of the Local Plan evidence base.
The A7 LCA report notes “an extensive mosaic of habitats along the Black Brook which forms a valuable wildlife corridor”. Issues and changes reported include “increased traffic during peak tourist periods, particularly those leading to key tourist destinations such as Dedham” and “increased flooding, especially along the watercourses, including Black Brook, which fall within Flood Zones 2 and 3. This could result in damage to natural habitats.”
The A7 Landscape Strategy states that “New development should be avoided, especially visually intrusive or incongruous structures, to protect the landscape quality and tranquillity of the Dedham Vale National Landscape and Stour Valley Project Area.”
The B7 LCA report notes ”predominantly arable landscape characterised by large open fields in the south and smaller more irregular fields in the north.” Issues and changes reported include “further ribbon development on the series of roads which connect Langham, Lamb Corner and Dedham Heath” and “disturbance to landscape character as a result of noise and movement associated with the main A12 road corridor and development on the northern edge of Colchester.”
The B7 Landscape Strategy declares that “The overall strategy for the Langham Farmland Plateau LCA is to conserve and enhance the rural landscape” and “Visually intrusive and incongruous development should be avoided, particularly in the north to protect the landscape quality and tranquillity of the Dedham Vale National Landscape.”
Further B7 Guidance includes “Protect the relative tranquillity away from urban influences, particularly in the north within and close to the Dedham Vale National Landscape”
These LCA reports demonstrate that the risk of harm to the Dedham Vale National Landscape is clearly recognised. However, this has not been considered when assessing the site for Policy PP37. The screening proposed in PP37 falls far short of properly mitigating the risk of harm, let alone making any positive contribution to furthering the statutory purposes of the National Landscape.
In reality, the proposed housing growth will have a number of adverse effects on the National Landscape, as explained in more detail in APPENDIX 4: DEDHAM VALE NATIONAL LANDSCAPE IMPACTS.
Policy PP37 cannot therefore meet the onerous requirements of section 245 of the Levelling-up and Regeneration Act 2023. It must be removed from the Local Plan.

6: AVIATION AND PUBLIC SAFETY CONSIDERATIONS
The draft site allocation is currently incompatible with the 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.
Boxted Airfield is both a significant WW2 heritage asset and a working general aviation airfield with an Approach Surface that overflies the western part of the proposed development site. It has been used for displays and memorial events on a number of occasions by flying clubs, including Suffolk Coastal Strut.
The proposed layout plan put forward by the land agent disregards the need for a no-build safeguarding zone along the flight path north of Park Lane. This is a fundamental oversight, which would limit the level of development west of Footpath 46 and reduce housing capacity.

7: LACK OF PLAN WITH FUNDING PROPOSALS TO DELIVER ESSENTIAL INFRASTRUCTURE UPGRADES
7.1 Longstanding 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 able to have been 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.
More detail on Langham’s sewerage situation, how CCC has failed to recognise the extent to which these issues render Policy PP37 wholly undeliverable, and how these failings will lead to a breach of the Habitats Regulation if the policy remains in the Local Plan, is set out in APPENDIX 9: LANGHAM SEWERAGE AND DRAINAGE REPORT.
7.2 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 (DWMP) (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.
No deliverable plans to resolve this showstopper issue have been identified anywhere within Colchester City Councils’ Evidence Base for the draft new Local Plan, and there is no mechanism available for developers to contribute towards upgrades to water and sewerage infrastructure. 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-only 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 nothing to suggest that the EA would deviate from this position for the development in PP37.
Even if an on-site treatment facility were to be provided as part of an overall solution, this may require an extensive cordon sanitaire in excess of 200 metres to accommodate odour and fly nuisance concerns. This would again impact on the development capacity and suitability of the development, which weighs against the strategic allocation.

7.3 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, cutting across the exit lane from a road side fuel station on the main A12 dual carriageway. The safety implications of a significant increase in traffic utilising the Langham/Ardleigh junction from the northbound carriageway of the A12 do not appear to have been considered, despite the spacing between the on-slip from the service station and the off-slip for the junction being less than 100m and significantly below current DMRB requirements. It 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. This junction will need to be re-designed to improve road safety with the dramatic increase in local traffic entering Langham. Unless this is done, the development will have an unacceptable impact on highway safety in this location, contrary to NPPF paragraph 116.
It should also be noted that forcing local traffic to use the strategic road network for local trips is contrary to highway policy, and should be avoided wherever possible.
Other improvements are likely to be required at the Park Lane/Wick Road junction and the Birchwood Road/Wick Road junctions, both of which suffer from restricted visibility which will pose increased safety risks associated with the dramatic traffic growth associated with the proposed development.
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. This would need to be included in the viability planning of the development, but also add to the undesirable urbanising of the village, which would effectively become a physically severed extension to Colchester. Further, the impact of the volume of cars associated with the allocation on the existing village roads, including opposite the primary school, has not been adequately considered, with the policy lacking any measures to ensure safety and encourage active travel within the settlement boundary of Langham village itself.
The key local road link between Langham and Colchester is Langham Lane. It is already a well-utilised route, serving in part as a ‘rat run’ to and from the A12. Like many minor roads and lanes, it suffers from continual pot holes created by the level of use and seldom gets maintained and repaired. Loading this route with a reasonable proportion of the traffic flows from 900 new dwellings will only exacerbate the situation and make it even less attractive for use by cyclists and pedestrians.
Assessment of Policy PP37 also fails to recognise the existing issues affecting connectivity. Key among these is the now-infamous damaged Severalls Lane bridge over the A12. This has remained unrepaired for 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 in the two villages. No proposals for the repair of this bridge form part of the requirements for Policy PP37, despite its clear importance to securing existing connectivity.
7.4 No credible and costed plan to manage projected increased 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. The focus appears to have been on traffic arriving from the A120 exit slip road, with no obvious recognition of the compounding effects of increased traffic arriving from Langham via the A12 exit slip road.
7.5 No credible and costed delivery plan for increased education and health capacity provision to underpin this draft strategic site allocation.
Impacts on education and health provision are considered in more detail in APPENDIX 10: EDUCATION and APPENDIX 11: HEALTHCARE respectively.

8: LACK OF PLAN WITH FUNDING PROPOSALS TO DELIVER ESSENTIAL LOCAL COMMUNITY AMENITIES
8.1 No evidence of any serious masterplanning preparatory work by either site promotors MacMic or CCC
Neither Colchester City Council nor site promoters MacMic have been able or willing to supply Langham Parish Council with a key for their masterplan diagram when approached in late November 2025. Colchester City Council were unable to supply it and referred us to the site promoters. The site promoters were unwilling to supply it when asked, because the masterplan was “currently under review” and they felt it inappropriate to share it with us until the review was finished. As a result, the consultation on Policy PP37 is itself inadequate as the policy cannot be reviewed with an understanding of the proposed masterplanning, and the extent to which that masterplan may address or undermine the wording of Policy PP37.
From the extremely limited email and telephone engagement between Langham Parish Council and MacMic, it became clear that Mac Mic were not even aware of the dual ownership of the 40 hectare land parcel, until advised of this by Langham Parish Council in July 2025.
The layout plan is unduly basic and not fit for purpose to demonstrate how a strategic development of this scale could be both assessed from a planning policy point of view, developed and phased. The lack of promotional detail and due diligence surveys etc, is conspicuous by its absence and simply reaffirms LPC’s suspicions over the speculative nature of the draft allocation. It may well be the case that the lack of background work and associated resourcing here, reflects the promoters fears that the planning merits of development are so far off the mark, it is not worth spending the money on. However, we can see why they are prepared to ride on the coat tails of the Council, who are testing the water by extending the settlement boundary in this way, despite the obvious collision with good planning practice.
In this way, the promoter has nothing to lose and its lack of investment in the planning process to date here has probably been a wise choice in any event, as the site is unlikely to pass the soundness tests required by the Government if it gets as far as the public examination, which it hopefully won’t.
8.2 No serious engagement with the local community or even the Parish Council
Despite a request in late November 2025, MacMic have been unwilling to meet face to face with Langham Parish Council until after the Regulation 18 consultation has closed.
Colchester City Council have similarly advised Langham Parish Council that any detailed dialogue must wait until after completion of the Regulation 18 consultation. This is particularly disappointing especially given the guidance set out in the NPPF and NPPG which recommends early, proportionate and effective engagement between plan makers, communities and other organisations. It seems that CCC has dug itself into a hole by trying to rush through a plan in an attempt to maintain a housing land supply irrespective of planning merits or community opinion and preferences. However, it is hoped that the position will be rectified to avoid further unnecessary silo working and conflict.
It is not possible to fully respond to the proposals in Policy PP37 as they have not been adequately shared. The consultation has not met the required standards of transparency, effectiveness and fairness, and has not provided enough information to ensure that those consulted understand the issues and can give informed responses as the Council and developer are refusing to disclose key information about the proposals in Policy PP37.

9. NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s SPATIAL STRATEGY (POLICY ST3)
9.1 Extreme misalignment with Colchester City Council’s Settlement Hierarchy
Colchester City Council’s Settlement Hierarchy is a key element of the Spatial Strategy Policy. The settlement hierarchy “identifies medium and small settlements where growth is allocated appropriate to the size of the settlement and its constraints”. The hierarchy identifies 13 medium settlements, one of which is Langham. Above the medium settlements, the hierarchy identifies 3 large settlements, 4 growth and opportunity areas, and at the very top of the hierarchy, Colchester Urban Area.
Langham has been allocated almost as much new housing (910) as the three large settlements combined (1120). Across the whole of Colchester, Langham Parish represents 0.5% of the City population, but has been allocated nearly 5% of the total new housing growth. This extreme mismatch, which would quadruple the existing village population, is entirely at odds with the requirement that growth is appropriate to the size of the settlement and its constraints.
9.2 Failure to respect distinctive character and role of existing settlements
Policy ST3 requires that existing settlements “maintain their distinctive character and role by avoiding harmful coalescence between them and through conserving their setting. New development will be required to respect the character and appearance of landscapes and the built environment and preserve or enhance the historic environment and biodiversity to safeguard the character of the City.” The proposed Langham allocation fails to comply with almost all of these requirements. Far from complying with this policy, the allocation is instead presented as an opportunity to fundamentally change the character of Langham by combining the two core settlement areas. See APPENDIX 8: LANDSCAPE AND HERITAGE REPORT once again for more explanatory details.

10: NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s PLACE SHAPING PRINCIPLES (POLICY ST8)
10.1 Failure to reflect and enhance local character, heritage and distinctiveness
The proposed Langham allocation notably fails to comply with the principles in paragraphs e, f and g of Policy ST8. See APPENDIX 8: LANDSCAPE AND HERITAGE REPORT for further details.
10.2 Failure to ensure good access to public transport and reduce reliance on cars
The proposed Langham allocation fails notably to comply with the principles in paragraphs h and k, requiring well-connected places that prioritise alternative transport above the use of private cars, and locating development in close proximity to existing and proposed public transport connections.
First, as has been established already in this report, there are no plans to create a new local centre of the proposed development. Secondly, Langham’s remoteness from key services providing most important daily needs will enforce rather than reduce reliance on cars. Policy PP37 would effectively create a large car-based satellite housing estate physically separated and remote from Colchester or any other sustainable settlement and it is hoped CCC will redress this unsustainable development option in favour of a more suitable alternative solution.
For further details on public transport challenges see APPENDIX 5: LANGHAM PUBLIC TRANSPORT REPORT.
10.3 Failure to protect the amenity of existing and future residents with regard to noise, vibration, smell, light pollution etc
The proposed Langham allocation also fails to comply with the principle in paragraph n, with little-to-no consideration given to the practical reality of the suggested on-site wastewater treatment, or the impact of development on existing issues of sewage flooding. On-site treatment will be noisy and smelly, and will be centrally located within the village affecting both existing and future residents on a permanent basis. The impact of light pollution from a large development, street lights and increased vehicles, has also not been considered despite Langham benefitting from relatively dark skies given its proximity to the Dedham Vale National Landscape.

11: NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s LANDSCAPE POLICY (LC1) AND RETENTION OF OPEN SPACE POLICY (GN6)
11.1 Lack of safeguarding of local landscape character and rural openness
The proposed large Langham allocation fails notably to comply with criterion a of LC1, which requires that development “must safeguard or strengthen tranquillity, features and patterns that contribute to the landscape character and local distinctiveness of the area, protect rural openness and sense of place and protect natural landscape features where thy make a contribution to the historic environment.” See APPENDIX 8: LANDSCAPE AND HERITAGE REPORT for further details of the non-compliances.
11.2 Destruction of amenity value of central village PRoW network
The proposed Langham allocation fails to comply with Policy GN6, which seeks to protect and enhance existing open spaces. The area of the proposed development currently offers a delightful network of rural footpaths which are heavily used by many residents for leisure walking, dog-walking, and also for active travel between the Langham Moor and Langham Wick built up areas of the village. These will be lost, and whilst access would be retained, this would be of a fundamentally different nature on urban pavements along new roads within the development, and all desirability for recreational purposes will be lost. See APPENDIX 8: LANDSCAPE AND HERITAGE REPORT for further details and explanatory maps.

12: NON-COMPLIANCES WITH COLCHESTER CITY COUNCIL’s CLIMATE AND NET-ZERO GOALS
12.1 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 add in the region of 2,000 additional, heavily used cars to the highest car-use MSOA (MSOA 001) in Colchester, disproportionately increasing carbon emissions in comparison to an equivalent development in a more sustainable location.
12.2 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 mile 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 need for cyclists to mix with traffic on Langham Lane. Consistent with LTN 1/20, anything less than a fully kerbed cycle track will be unsuitable for all but a few people and will exclude most potential users due to safety concerns. A scheme is proposed within the infrastructure project schedule, with an indicative cost of £9.2m and indicative timing of 2034-37, but with no funding secured it is hard to imagine that such a scheme will prove cost effective, functionally effective and therefore deliverable in these timescales.
12.3 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, but this imbalance can be addressed through appropriate site selection that avoids encouraging private car use. Policies such as PP37 therefore fundamentally undermine the achievement of policies NZ1 and NZ2, and should be removed to ensure the Local Plan is consistently applied.
12.4 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. This issue is exacerbated by the allocation in Policy PP37 where no funded infrastructure improvements are identified that will make a material contribution towards modal shift, leaving it likely that such necessary works will never be implemented.

13: NON-COMPLIANCE WITH COLCHESTER CITY COUNCIL’s TRANSPORT MODAL SHIFT IMPERATIVE
13.1 The large draft Langham housing allocation runs totally counter to Colchester City Council’s well documented and self-acknowledgedly 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”. Care should be taken not to prioritise longer journeys over the more frequent shorter journeys to key services, as doing so risks both encouraging car use and making it more challenging to use alternative transport modes and active travel. The allocation in Langham does just this, focusing solely on the ability to access the strategic road network for long journeys and largely disregarding the challenges of accessing local services without being forced to use private car.
13.2 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 environment
Decarbonisation of the transport sector should be promoted and implemented
The allocation in Langham fails to effectively implement these policies, and demonstrates that site selection has not been undertaken to identify sites where residents can carry out the majority of their journeys by alternative means. These policies are vital to ensuring those without access to a car are not left isolated from important social, educational, economic and healthcare services. By focusing on how such services can be accessed without a private car, it becomes clear just how poorly connected the allocation in Policy PP37 is, and how challenging individuals and families will find daily life if they cannot access or afford a private car.

14: NON-COMPLIANCES WITH NATIONAL PLANNING POLICY FRAMEWORK (NPPF)
The draft Langham allocation undermines the compliance of the Local Plan with the NPPF, calling into doubt its soundness. The allocation in Policy PP37 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,e; 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;
As set out in this objection, Policy PP37 is not sustainable development, being on a wholly disproportionate scale. The lack of funding for infrastructure means it is unsecured and does not align with the proposed growth. The location requires and encourages private car use, undermining efforts elsewhere in the Local Plan to mitigate climate change.

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;
Policy PP37 represents an excess of aspiration at the expense of deliverability. The requirement for significant infrastructure upgrades, none of which are planned or capable of being contributed to by a developer, leaves the policy incapable of being delivered. The outcome of consultation with AWS has been to show that no investment is planned at Langham WRC, yet rather than shape the policy allocations, the Council has ignored this fundamental impediment. The policy in PP37 is incapable of delivering the housing allocation it purports to provide.

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.
Policy PP37 focuses entirely on housing provision, at the expense of employment, retail, leisure and other commercial development. Critical wastewater issues have been glossed over but left unresolved. The policy is inconsistent with the strategies in the Local Plan for the selection of sites for housing.

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.
Policy PP37 requires significant upgrades at Langham WRC for even one property to be built out; however no such improvements are planned for the period up to 2050. The likely timescale for delivery is not within the next 15 years, and is unlikely to be possible within the next 30 years, and therefore fails to meet the strategic requirements of the NPPF.

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.
Policy PP37 identifies the critical need to wastewater management infrastructure, as well as infrastructure improvements to support active travel. However, there is no mechanism for developers or the planning system to contribute to improvements to infrastructure operated by sewerage undertakers, and the funding shortfalls for transport infrastructure undermine 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.
In order for policy PP37 to be justified, the Council must show that they have considered genuine alternatives to the allocation, that they have proportionate evidence supporting the scale and location of the allocation, and that Langham represents an appropriate strategy when compared to other settlement options. The Council’s evidence base, particularly the Infrastructure Delivery Plan, directly contradicts the allocation’s appropriateness. Policy PP37 has not been and cannot be justified. Policy PP37 is also not consistent with national policy, as set out in this section, and fails to comply with the Council’s statutory obligations under the Habitats Regulations and the Levelling-up and Regeneration Act 2023.

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.
Policy PP37 is not well located for the reasons set out in this objection, and lacks the necessary infrastructure to be sustainable. The policy is not supported by the community that would host it, and the location precludes meaningful compliance with many strategic policies, particularly around sustainability.

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.
Policy PP37 cannot be considered to be an edge of centre or out of centre proposal as Langham village is too small to properly support this. It is therefore a rural development a significant distance from anywhere that could be considered a town centre. Preference should have been given to sites that are edge of centre or out of centre proposals, but this has not been done.

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.
The proposal in Policy PP37 does not include any new local centre to support the development. Existing facilities in Langham largely rely on volunteers, and are of a size and scale appropriate to the existing village. These facilities cannot support a population that is quadrupled in size, and will be overstretched if they survive the additional burden from serving such an expanded settlement. Consideration of the impact of the allocation on existing services has not been adequately considered and appropriate provision has not been made, contrary to this NPPF requirement.

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.
The Infrastructure Delivery Plan confirms that there is insufficient primary school availability for the proposed allocation in Policy PP37, but also recognises that Langham Primary School is constrained and cannot be expanded to accommodate the number of pupils required and that the allocation is too small to justify requiring a new primary school is built. Great weight must be given against the development due to this failure to ensure adequate primary school education will be available.

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.
Policy PP37 will not protect or enhance public rights of way, instead altering the nature of the public rights of way into urban pavements. No greater connectivity is proposed.

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.
The safety risks associated with the A12 junction have not been given due consideration, and the absence of a mechanism to secure funding for transport improvements to support modal shift casts serious doubt over the deliverability of this required mitigation. Policy PP37 perpetuates private car use, and will fail to deliver well-designed, sustainable and popular places.

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.
Policy PP37 fundamentally fails to meet this test due to the distance of the site from the greater Colchester area, meaning that modal shift to cycling is less likely even with enhanced cycling infrastructure. A genuine choice of transport modes is not possible due to the distance of Langham from key services. The lack of funding for cycling improvements demonstrates the failure to comply with this aspect of the NPPF.

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.
The housing need in Langham is a fraction of the proposed allocation in Policy PP37, and cannot be said to meet the objectively assessed need. The need for housing in the wider Colchester area should not be conflated with local need, as building houses in the wrong place will not effectively address the wider need, and development that is not adequately supported by infrastructure improvements and access to services will not make effective use of the 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.
As set out in this objection, the challenges of improving wastewater infrastructure at Langham WRC have been largely ignored, along with the absence of any mechanism to deliver such improvements. A strategy to secure funding for transport improvements is notably absent and made more challenging due to the distance over which cycleway upgrades would be required. The desirability of maintaining the area’s prevailing character and setting has been entirely ignored, and the impacts on the health and wellbeing of existing and future residents have been dismissed. Langham is unsuited to supporting the scale of development in Policy PP37, and fails to meet this policy requirement as a result.

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.
It is impossible for a developer to have any certainty as to what will be possible in light of the proposed planning condition, amounting to a moratorium on development, that capacity at Langham WRC must be in place before an application will be considered. It is not possible to provide any further assessment of the extent to which the allocation in Policy PP37 may set out a clear design vision due to the Council and the developer refusing to provide any detail about the masterplan for Policy PP37. Langham Parish Council therefore reserves the right to make further representations about the design vision for this allocation once this information has been made available.

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; 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 users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.
Policy PP37 will fundamentally alter the character of Langham village. However, it is not possible to make any further comment about how the masterplan for PP37 may comply with this NPPF requirement as the Council and developer have refused to share details about the masterplan. Langham Parish Council reserves the right to make further representations about the masterplan’s compliance with this part of the NPPF.

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.
The expected consequence of climate change is for winters to become wetter and the summers drier. As set out in detail in this objection, a development on the scale proposed in Policy PP37 is expected to lead to the worsening of the existing flood risk from sewer, as the high water table and infiltration issues result in the system being overloaded. Policy PP37 relies heavily on private car use, with the village’s distance from Colchester being sufficient that modal shift is unlikely to be significant. Policy PP37 therefore worsens the resilience of the existing village to climate change and will result in greater carbon emissions than alternative sites.

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.
Little to no consideration has been given to how the allocation in PP37 will impact the Langham Farmland Plateau landscape character area. The policy does not comply with the Council’s own evidence base in the Landscape Character Area, and disregards the value of the rural environment in the character of the village and in providing habitat for endangered species such as skylark.

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.
Policy PP37 is located in the setting of the Dedham Vale National Landscape, yet there is no clear strategy for how the allocation will further the purpose of the National Landscape. It is unclear how the allocation has been ‘sensitively located’ or what measures have been taken to avoid or minimise adverse impacts on the National Landscape, particularly in relation to impacts on tranquillity from increased traffic and light pollution affecting dark skies.

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.
Much of the allocation’s ability to meet this requirement is set out in the masterplan. However, as the Council and developer have not provided any clarification and refused to provide further detail, it is not possible to comment on the policy’s compliance with this part of the NPPF at this time. However, it is noted that whilst the intention is to retain existing hedgerows, housing development will be located on habitat used by nesting skylark, who are particularly at risk from the loss of habitat. Langham Parish Council reserves the right to make further comment in relation to this matter once further detail of the masterplan has been made available.

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 life; 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.
The Council has not considered the noise and odour disruption from a potential on-site wastewater treatment facility, located in the centre of Langham village. It also hasn’t given adequate consideration to the loss of tranquillity in and around Langham, nor on the impacts of light pollution on dark skies and nature conservation from development in the setting of Dedham Vale National Landscape.

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.
The Council has not adequately assessed the impact of fundamental changes to the character of Langham village on its designated heritage assets. This must not be deferred until a planning application is made under Policy PP37, as measures required to avoid harm to designated assets, and to the setting of designated assets, must be understood, secured in the policy and incorporated into the masterplan. In the absence of an adequate heritage assessment, the harm to Langham’s assets is unknown, and it is not possible to understand if the allocation is acceptable. The clear risk is that substantial harm would be caused by any development built out under Policy PP37, and that it could therefore not be granted planning permission, making the allocation ultimately undeliverable.

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.
The potential for harm to Langham’s designated assets through development in their setting pursuant to Policy PP37 has not been justified, particularly given the availability of other sites without the same constraints.

15: NON-DELIVERABILITY
15.1 The cumulative impact of all the issues, challenges and uncertainties raised above means that the site allocation is highly unlikely to be capable of delivery within the lifetime of the Local Plan, and it is therefore not in compliance with the NPPF deliverability definition.
NPPF defines a site as deliverable if it is available now, offers a suitable location for development, and there is a realistic prospect that housing will be delivered on the site within five years.
Issues arising from multiple land ownership, the adjacent airfield, longstanding and unresolved sewage infrastructure problems, and substandard road junctions on to the A12, amongst others, render deliverability on a five year timescale impossible, and delivery within 15 years highly questionable.

16: PLANMAKING PROCESS WEAKNESSES AND DISCREPANCIES
16.1 Substantial changes to housing numbers for this site, very late in plan development
Colchester City Council’s evidence base documentation includes a variety of different housing volume scenarios for Langham. A summer 2024 transport modelling scenario considered a range of 100 (low) to 450 (high). The Infrastructure Audit and Delivery Plan Stage 3 report published on 7th February 2025 utilised as a modelling input an emerging allocation scenario (dated November 2024) that included 286 new houses in Langham. Subsequent to this November 2024 scenario, new evidence emerged from the interim Water Cycle Study, confirming the total lack of sewage treatment capacity at Langham WRC. One might imagine that proposed Langham housing numbers would therefore be reduced in the next evidence iteration, but instead of this, the February 2025 draft Regulation 18 Local Plan documentation amended Langham’s proposed housing numbers upwards from 286 to 910.
The huge discrepancy in the housing numbers assessed in Langham also draws into question the reliability of the Council’s evidence base. It is impossible to tell if an assessment has properly assessed 910 houses allocated in Langham, or if it is based on a different, lower number. It is therefore impossible to confidently review the Local Plan documents to understand the impacts of the allocations in Langham as these may have been underreported many times over. Notwithstanding this, to the extent the evidence base may have assessed a lower allocation than that proposed, the impacts and non-compliance with the NPPF are abundantly clear. The conclusion must be that no allocation in Langham can be sustained within this Local Plan.

16.2 Inconsistent application of site assessment decision making criteria
In the October 2025 Summary of Sites Evidence, it is instructive to note the contrast between site assessments for site 10685 in Boxted and site 10664 in Langham. Site 10685 in Boxted was discounted because “Development of the scale of 10685 would not relate well to the scale and nature of the village.” Site 10685 in Boxted is only two-thirds of the size of site 10664 in Langham. Boxted is also a larger village, with a population 50% greater than Langham. Given that Boxted and Langham are adjacent villages with similar characteristics, there would appear to be a gross inconsistency in application of site assessment criteria.

17: EXTREME MISMATCH WITH LOCAL HOUSING NEEDS
17.1 Langham Parish Council’s professionally commissioned Housing Needs Survey and Housing Needs Assessment reports indicate a local housing need of between 60 and 120 new homes over the new Local Plan period (far below the 910 homes being proposed)
See APPENDICES 1, 2 and 3 to read these comprehensive reports in full.
17.2 Much of this local housing could be met by the unbuilt allocations from the current local plan (57 homes)
The 910 are therefore clearly addressing a non-local need, with the policy operating to greatly increase the size of Langham without providing critical infrastructure and services to support this, driving increased car usage.
17.3 The largest Langham site allocation in the current plan (46 homes) has only been 50% built, and even these 23 homes took more than 3 years to sell and/or rent.
Noting Langham’s housing price premium over urban Colchester, it is likely that properties built under Policy PP37 would need to be marketed to people moving outwards from London, better able to afford properties than those seeking to move outwards from Colchester. This demographic will consist primarily of commuters, and the distance of Langham from Colchester rail stations further reinforces that private car use will be encouraged by the development. The policy fails to provide a solution for Colchester City Council’s current affordable housing shortage, and is contrary to the NPPF requirement to locate housing development where it is objectively needed.
18: SITE COMMERCIAL VIABILITY DOUBTS
18.1 The strategic site viability assessments (undertaken by Newmark for Colchester City Council) use many generic, non-site specific, high level assumptions across all 12 strategic sites. These include common assumptions on S106 costs per unit and infrastructure/abnormals costs per unit.
18.2 It is therefore likely that site-specific sewerage and highways costs (in particular) have been seriously underestimated.
18.3 Lack of Langham-specific Infrastructure Development Plan exacerbates existing poor connectivity to services.
Please see APPENDIX 12: LANGHAM INFRASTRUCTURE ASSESSMENT REPORT to read Langham Parish Council’s provisional assessment of project requirements and costs, building where possible on CCC’s overall IDP, and attempting to fill in some obvious gaps.


Langham Parish Council
12th January 2026

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.

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.

We are supportive of the proposed residential allocation.

The paddock land parcel concerned measures c2 acres and is situated adjacent to/at the rear of another land parcel, subject of a recent planning permission (ref no. 221510, dated 11th Dec 2025) for 12 dwellings. The subject land is of a conforming rectangular shape and configuration allowing an efficient residential scheme layout. Access is proposed to be taken off Wick Road via the current consented scheme. We consider that the site, if efficiently laid out and used has ample scope to accommodate more than 10 dwellings/units, so we would like recommend that the site capacity is adjusted to read 'a minimum of 10 dwellings' but to anticipate c 12 to 15 units.

Our clients Foul water discharge solution proposes incorporation of several on site private treatment plans, each serving several dwellings. BNG will either involve inclusion of neighbouring land owned by our client or securing of appropriate credits.

Langham is a rural village of around 900 residents, the proposed increase of 900 new dwellings is going to impact severely on the village and surrounding areas. The existing roads are at present heavily congested especially on school road at peak times at the start and end of the school day. Public transport is very infrequent and local services are at capacity. Our sewage system is at a very basic level and can’t at present cope with demand from the village. Our water supply is outdated and pipe work needs replacing.

The attached report from engineers, Superstructures, in relation to an on site private sewage/waste water treatment plant solution is submitted and to be read in conjunction with rep no 13210.

See attachment with detailed comments on numerous policies. Anglian Water welcomes the opportunity to contribute comments on the Draft
Local Plan for Colchester City Council. We consider that the Plan is well set out with in relation
to managing flood risk, surface water and wastewater, and enabling water efficiency. We
recognise the challenges for meeting the uplift in housing requirements and the
infrastructure required to help deliver future growth across the district, with the main
focus being Colchester and the larger towns.
We have raised some policy matters relating to consistency between policies addressing surface
water flood risk, water supply, and wastewater, and how these matters are attributed to site
allocation policies.
We look forward to continuing our positive and proactive discussions with the Council in
respect of our comments and the next iteration of the Local Plan, including supporting updates
to the evidence base if required

Landscape and Footpaths
The central farmland between Langham Moor and Langham Wick forms the village’s historic rural core, (it’s not an infill site) and large-scale development would fundamentally damage its landscape character and rural identity. It would urbanise open countryside, harm long views toward the Dedham National Landscape, and degrade numerous well-used footpaths—I belong to a walking group and regularly use these footpaths. The proposals would also harm the historic airfield landscape and the setting of the Station 150 Monument. With no supporting evidence, the allocations conflict with key NPPF paragraphs 35, 130–135, 191, and 200–209 and are therefore unsound.

See Full Submission attachment

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

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

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

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