Comments as follows:
1. Positive to see the Roman River Corridor inclusion, and to see the high value Colne Valley landscapes recognised in the Landscape Character Assessment.
2. Positive to see mobility hubs and increased attempts at providing for sustainable transport.
3. Concern that the Brownfield Land Register remains very limited and focuses almost entirely on the urban area of Colchester. More should be done to proactively identify brownfield sites across the entire city boundary.
4. Concern that affordable housing delivery has only been 16% per annum on average for the past eight years and that the viability appraisals that accompany this plan must be rigrously tested to ensure that they are robust.
5. Concern that the strategy for Eight Ash Green results in car-dependent ribbon development along the 1124. Site PP32 should not be allocated. It represents unacceptable encroachment into the countryside.
6. Further concern that PP32 conflicts with the previous and latest Colchester Landscape Character Assesssments which seek to protect the Colne Valley. The site will be highly visible from Fordham and Chappel and cannot be screened. See attached by way of example. PP32 should not be allocated.
7. Allocation of Marks Tey North. All housing should be concentrated to the south of the site, in a high density development. Much of the Roman River must be kept inaccessible from residents and their dogs to ensure nature can flourish in the Nature Recovery area. The development must be safely connected to Marks Tey station by pedestrian and bike paths that do not use the polluted A120.
8. There should be minimum density requirements for all sites, not just urban ones.
9. The policy wording for conversions should change from 'only supported' to 'strongly supported.
10. There would be a policy to strongly support the bringing back of empty homes into use. An additional SA Monitoring indicator is required for number of homes brought back into use.

This plan is not detailed and will be impossible to impliment

SA2, there is a Criteria for "loss of best and most versatile agricultural land?", but no listed Monitoring Indicator.

SA8, the Criteria lists various types or protection and enhancement, but some of the Monitoring is basically recording damage done by developments approved despite being against good advice, so oh dear that's been damaged/lost too late now, i.e. "Number of planning applications approved contrary to advice given by the EA" and "Number of planning approvals that generated any adverse impacts on sites of acknowledged biodiversity importance".

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.