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

We are generally supportive of the thrust of the above policy requirements, and subject to some relatively minor modifications they are considered deliverable. However, we do have several comments.

5.4 In respect of point d), we agree that the development of the Site should be implemented in a manner that minimises risk of future coalescence between West Bergholt and Colchester, and reduces perception of any coalescence that may arise from development of the Site. However, we suggest that the current wording of this criterion does not provide clarity to a future decision-maker as to how to consider the issue in determining a planning application.

5.5 In addition, whilst this presumably refers to the Neighbourhood Plan, and how this seeks to avoid coalescence, it does not account for a future, updated/ alternative Neighbourhood Plan. This could set out an alternative approach which may not be appropriate to refer to in this policy.

5.6 We suggest that, as an alternative which would still achieve the objectives of the policy, this criterion makes reference to proposals for development of the Site being required to demonstrate how they have provide a new, robust, settlement edge that is imbued with a degree of permanence, minimising the risk of future encroachment into the countryside between West Bergholt in the Colchester to the extent that it could result in the coalescence of the two settlements.

5.7 In respect of criterion h), we consider this is unjustified and inappropriate.

5.8 Water companies are required to ensure that sewerage infrastructure is planned and funded to provide the necessary capacity to support growth proposed through new Local Plans. Water companies must create Drainage and Wastewater Management Plans (DWMPs) which are required to align with Local Plans to consider current and future development needs. Additionally, water companies plan in 5-year cycles (i.e. Asset Management Periods), and are not looking over the 15- year plus plan period the new Local Plan will address.

5.9 In short, the water company is expected to collaborate with local authorities to ensure that sewerage infrastructure is planned and funded in line with projected growth in a Local Plan, i.e. once allocations are proposed, the water company should ensure it plans to provide the respective capacity. It is not the case that any existing water recycling capacity issues should be determining where or when growth can be delivered. On the contrary, the Local Plan should perform this role, and water companies react to ensure this can be achieved.

5.10 Similarly, we suggest that there are aspects of criterion k) that are seemingly seeking to make the developer of the allocation responsible for matters which are the responsibility of water companies.

5.11 Finally, the reference in the final paragraph to the need for development to the Site to conform to the 2019 Neighbourhood Plan policies where up to date and relevant is considered, at best, superfluous. The made Neighbourhood Plan is already part of the Development Plan and thus relevant and up to date policies would need to be considered in respect of any application for development of the Site, regardless of the new Local Plan. Additionally, by specifically referencing the 2019 Neighbourhood Plan, this could give rise to potentially problems in the event that an updated/ revised Neighbourhood Plan was to be prepared.

5.12 We wish to stress that we wish to work collaboratively with the City and Parish Councils regarding the development of the Site, and would welcome discussions with the Councils and other stakeholders as the plan progresses.

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.