Great Tey Neighbourhood Plan 2022-2033 (Regulation 16)

Chapter 3 – Vision and Objectives
Neighbourhood Plan Objectives
ECC supports Objective 4 in terms of enhancing the delivery and funding of infrastructure. It is
noted that the plan does not allocate any sites for housing or employment development, therefore
the extent of developer contributions likely to be sought is minimal. However, in order to help any
windfall development that may arise in the plan area, ECC considers reference should be made
to the ECC Developers' Guide for Infrastructure Contributions. This outlines the scope and range
of infrastructure towards which ECC may seek contributions from developers and landowners in
order to make development acceptable in planning terms.
Design codes and guidelines for design landscaping, access and movement and sustainability
Please refer to detailed comments regarding the Great Tey Design Guidelines and Codes (March
2022).
Chapter 4 – Design and Landscaping
Policy GTTEY1: Design
ECC recommend Criterion A also makes reference to new development being required to have
regard to the Essex Design Guide (EDG) as well as the Great Tey Design Guidelines. The EDG
contains a much wider scope, including a Highways Technical Manual; Sustainable Drainage
Systems Design Guide for Essex of which ECC is the statutory and/or Lead Authority; and
sections regarding Ageing Populations and Health and Wellbeing. More recent additions include
Planning for 5G and Solar Farm Guiding Principles.
A. Development should demonstrate high quality design and layout which respects the local
character of Great Tey having regard to identified in the Great Tey Design Guidelines and
Codes and the Essex Design Guide (or any successor documents).
ECC supports reference in Criterion vi. seeking development to `be optimised for energy
efficiency, targeting zero carbon emissions’ and in paragraph 6.3 for buildings to be built to the
highest possible standards to minimise their carbon footprint. ECC notes reference that the
Colchester Local Plan Section 2, Policy DM25 requires development of buildings to incorporate
measures to adapt to and mitigate climate change.
ECC strongly support developments which seek higher requirements for new homes than the
requirement to be in accordance with Building Regulations and go beyond Future Homes
Standard (FHS). ECC, through the Essex Climate and Planning Unit (CaPU). has recently
published a number of policy and evidence base documents to support emerging Local and
Neighbourhood Plans and the determination of planning applications to move towards net zero
development, which can be viewed here.
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
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It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Policy GTTEY2: Landscaping
Chapter 7 - Services, Commerce and Infrastructure
ECC recommend an additional Criterion C is added to the policy to support future proofing digital
connectivity and high-quality mobile coverage for all homes and businesses. It is acknowledged
that new development already has to provide access to high-speed broadband but NPPF,
paragraph 118 requires planning policies to support the expansion of electronic communications
networks, including next generation mobile technology (such as 5G) and full fibre broadband
connections. Policies should set out how high-quality digital infrastructure, providing access to
services from a range of providers, is expected to be delivered and upgraded over time; and
should prioritise full fibre connections to existing and new developments.
In January 2023, amendments were published to the Building Act requiring that new homes are
installed with the fastest broadband connections (gigabit) available within a cost cap. Even where
a gigabit-capable connection is not possible within this cost cap, the new homes will be futureproofed with physical infrastructure to support gigabit-capable connections when they become
available. This is also important given the increase in home working following the pandemic.
The EDG contains supplementary planning guidance for Planning for 5G and can be viewed here
and Planning Guidance for digital connectivity focused on fixed line broadband connections. ECC
has published its Digital Strategy for Essex (2022) which seeks to further expand digital
infrastructure and technologies.
ECC recommend an additional criterion to read:
Proposals for new developments or expansion of existing properties should be capable of
receiving gigabit speed and reliable mobile and broadband connectivity. Proposals will be
supported where the appropriate cabling and ducting is provided to the premises and linked to
infrastructure networks, enabling the fastest available connections. Where connectivity is not
currently available suitable ducting that can accept superfast broadband, fixed line gigabitcable broadband and/or 5G connectivity should be provided to the public highway or other
suitable location.
Non-Policy Action D: Maintaining Local Infrastructure Services
ECC recommend Non-Policy Action D is reviewed as it appears to refer to local infrastructure as
well as more nationally significant infrastructure, namely the Norwich to Tilbury NSIP project, as
outlined in paragraph 7.6.
ECC recommend that Action D only refers to local infrastructure that may arise from any new
development in the Plan area. For the purposes of this Action the widest reasonable definition of
infrastructure and infrastructure providers could be applied and set out in the supporting text.
The term infrastructure can include any structure, building, system facility and/or provision
required by an area for its social and/or economic function and/or wellbeing including (but not
exclusively): footways, cycleways, bridleways and highways; public transport; drainage, SuDs
and flood protection; waste recycling facilities; education and childcare; healthcare; sports,
leisure and recreation facilities; community and social facilities; cultural facilities, including
public art; emergency services; green infrastructure; open space; affordable housing; live/work
units and lifetime homes; broadband; and facilities for specific sections of the community such
as youth or the elderly.
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In addition, ECC seek reference is made to the ECC Developers' Guide for Infrastructure
Contributions, which outlines the scope and range of infrastructure towards which ECC may seek
contributions from developers and landowners in order to make development acceptable in
planning terms.
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Great Tey Design Guidelines and Codes (March 2022)
3.3 General principles and guidelines
ECC recommend design principle 2 should also refer to the `setting’ of heritage assets consistent
with NPPF, paragraph 201.
3.4 General design guidelines and codes
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
Code 2 Development affecting listed and unlisted heritage assets
With regards Design guideline 2, ECC recommend reference should also be made to the `setting’
of heritage assets consistent with NPPF, paragraph 201.
New development proposals should not be visually intrusive or block key views to and from
heritage assets and their setting, as shown in F.2. T
Code.3 Set in rural landscape/ development edges
With regards Design guideline 2, ECC supports new development conserving existing native trees
along lanes but consideration needs to be given to any impact on highway safety and visibility
splays. Detailed guidance is provided in the EDG - Highways Technical Manual - planting in sight
splays..
With regards Design guideline 7, ECC supports the principle of green corridors providing
additional pedestrian and cycle links. Please see comments to Code 8 with regards establishing
multifunctional greenways and their design requirements, namely to be consistent with Cycling
infrastructure design (LTN 1/20).
Code.4 Patterns of growth within the rural landscape
With regards Design guideline 2, ECC recommend reference is made to the need for new
development to also consider the `setting’ of heritage assets consistent with NPPF, paragraph
201.
New development in close proximity to designated and non-designated heritage assets and
their setting must propose green screenings to mitigate any unpleasant visual impact, while
also preserving key views;
With regards Design guideline 7, ECC recommends reference is also made to the need to
maintain safety along any lane for all users (pedestrians, cyclists, horseriders and vehicles). ECC
also recommend `increase’ is replaced by `impact’.
Any proposal that would adversely affect the physical appearance of a rural lane, or give rise
to an unacceptable impact increase on in the amount of traffic, noise, safety or disturbance
arising from traffic must be avoided.
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With regards Design guideline 8, ECC recommends reference is made to the multifunctional
green network strategy.
`… is encouraged to form part of the multifunctional green network strategy (no.4); and
With regards Design guideline 9, ECC recommend any signage is located so that it does not
impact upon visibility of the highway network and should be consulted as the highway authority.
All requests for signs need to comply with Traffic Signs Regulations and General Directions 2016
and other ECC policies. Any scheme investigation will also consider street clutter, available
highway land and relationship to any utility equipment. Usually the appropriate signs are identified
when a development is agreed and the impact of traffic on the wider network is assessed. Local
signage may also be progressed through the Colchester Local Highways Panel.
Code 7 Accessible and attractive footpath network/ access to the countryside
ECC recommend the correct terminology is consistently used with regards the terms ‘footpaths’
and ‘footways’ throughout the document. For example, pavements beside public roads are not
public footpaths and are better referenced as footways. Public footpaths are shown on definitive
maps recording Public Rights of Way where anyone has the legal right to use on foot.
ECC recommend the title is amended to refer to `footway and footpath’ network.
ECC suggest the following clarifications on this matter:
• Design guideline 1 – amend `footpaths’ to `footways’ as these relate to more urban streets
than Public Rights of Way (PRoW)
• Design guideline 2 - reference to `multifunctional’ should be included to read:
Where possible, new proposed footpaths should link up green spaces and woodlands to
create a network of multifunctional green walking routes and promote biodiversity. For
example, the Strategic Wildlife Corridors, as shown in F.44, could include footpath
connections and other green links that could connect new development and form part of
an a multifunctional integrated green infrastructure network;
• Design guideline 4 – reference should be made to new signposts being located so that it
does not impact upon visibility of the highway network and any proposals should be
considered by the highway authority. Please refer to comments regarding Code 4,
Guideline 7.
• Design guideline 5 – amend to `footpath’ to ‘footway’’
Code 8 Prioritise walking and cycling
ECC suggest the following clarifications on this matter:
• Paragraph 1 – refer to `There is an extensive network of footways and footpaths public
footpaths and rights of way in the parish.’
• Design guideline 2 – amend `favour’ to `prioritise’ to be consistent with the Code 8 title,
Design guideline 4 and the new Highway Code. The latter states that drivers must be
aware that pedestrians, cyclists, horse riders, carriage drivers and motorcyclists, as the
most vulnerable road users, should take priority over cars.
• Design guideline 2,3 and 4 – replace `footpath’ with `footway’.
Code 9 People-friendly streets and green links
ECC welcomes the requirement for new footpaths/footways to link up with green and blue
infrastructure to create a network of green walking routes and promote biodiversity. ECC
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recommend reference is made to establishing `multifunctional greenways’ to promote sustainable
and active travel movements and contribute to health and wellbeing.
ECC welcomes the aim to prioritise walking and cycling to help get people healthier and to gain
access with nature. ECC support the principle of establishing multifunctional greenways to
promote sustainable and active travel movements and contribute to health and wellbeing. Any
design of new routes will be required to be consistent with Cycling infrastructure design (LTN
1/20) and to be coherent (allow people to reach day to day destinations easily); direct, safe,
comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
Any pedestrian and cycle links being bordered with rich vegetation and trees should require
consultation with the highway authority given the potential danger to pedestrians and cyclists of
overhanging hedges as well as any impact on highway safety and visibility splays. Detailed
guidance is provided in the EDG - Highways Technical Manual - planting in sight splays. ECC
seeks to be consulted upon any relevant tree planting in proximity to the highway, walking and
cycling routes where the future height, breadth and root growth may impact upon user safety.
ECC recommend design guideline 1 is amended requiring street design being required to have
regard to the standards set out in the EDG - Highways Technical Manual. The prioritisation of
vulnerable users is also consistent with the Highway Code (see response to Code 8)
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
With regards Design guideline 2, ECC recommend reference to`streets should not be built to
maximise vehicle speed or capacity’ should be deleted and replaced with reference to the EDG
Highways Technical Manual - Street Type Table (A to H) in terms of the type of street and
recommended speed limit.
Within the development boundaries, streets should be constructed consistent with their street
type and speed limit, having regard to the EDG Highways Technical Manual - Street Type
Table (A to H) in not be built to maximise vehicle speed or capacity. A range of traffic calming
measures could be introduced by design
With regards Design guideline 4 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
With regards Design guideline 5 – ECC considers reference is made to multifunctional green
infrastructure, as they promote sustainable and active travel movements, contribute to health and
wellbeing, and can be incorporated within sustainable drainage measures (consistent with Code
12, Design principle 2).
Streets must respect the existing vegetation, while also incorporating new opportunities for
landscaping, multifunctional green infrastructure, which may incorporate and sustainable
drainage measures; and
With regards Design guideline 6 – ECC recommend the access street dimensions (page 35);
residential street key dimensions (page 37)and edge lanes key dimension (page 39) should be
reviewed against the EDG Highways Technical Manual - Street Type Table (A to H) for
consistency.
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Reference should be made to the provision of bus stops, where appropriate, which must provide
seating and shelter, raised kerb, ancillary infrastructure, real time information (where appropriate)
and be designed in keeping with the character of the local area. Further guidance is provided in
the EDG and can be found here.
Code 10 Parking and servicing
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They have
been subject to two consultations with LPAs and developers. The standards are being revised to
reflect changes in the new Use Class Orders and national planning policy. Different standards
are required in different areas based on levels of accessibility, namely town centres (highly
accessible); rural (poorly accessible); and other areas (moderately accessible). Details also cover
electric vehicle charging requirements for both residential and non-residential uses. More detailed
design guidance is also provided for both residential and commercial cycle parking taking account
of LTN 1/20 guidance.
With regards Design guideline 1 – please see comments to Code 15 Trees.
With regards Design guideline 4, ECC welcome the reference to the need to be able to charge
electric vehicles. Please se comments under Code.30 Electric vehicle charging points.
Code 11 Cycle parking
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. More
detailed design guidance is also provided for both residential and commercial cycle parking taking
account of LTN 1/20 guidance.
With regards Design guideline 3 – Houses without garages, the emerging parking standards state
that any external access to a location where bicycles can be stored should enable cycles not to
be wheeled through the house, preferably within the property boundary, as opposed to shared
facilities. The bike storage should be covered, secure and large enough to house the number of
bikes/spaces required in line with the standards for that type of use. The emerging standards
require a door width of at least 1.0m should be provided upon access to storage facilities when
provided within the footprint of the dwelling or as a freestanding shed. In flatted developments the
cycle store should be incorporated within the building but accessed directly from the outside with
a minimum recommended door width of 1.2m.
ECC recommend the following amendment and to Figure 33.
When provided within the footprint of the dwelling or as a free standing shed, cycle parking
should be accessed by means of a door at least 1.0m 900mm and the structure should be at
least 2m deep; and
With regards Design guideline 1 – Houses with garages – reference is made to minimum garage
size being 7m x 3m to allow space for cycle storage. This is consistent with the emerging parking
standards dimensions, which includes space for storage and cycle parking.
Code 12 Create a green network
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ECC seek clarification as to whether this section will be reviewed to take account of the published
National Green Infrastructure Framework (2023) and the Essex Green Infrastructure Strategy
(2020) and the Essex Green Infrastructure Standards (June 2022).
ECC support the principle of establishing multifunctional greenways to promote sustainable and
active travel movements, contribute to health and wellbeing and increase opportunities for access
to nature. Any design of new routes will be required to be consistent with Cycling infrastructure
design (LTN 1/20) and to be coherent (allow people to reach day to day destinations easily);
direct, safe, comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
The title should be amended to refer to `multifunctional green network’ with similar references in:
• Paragraph 1 - ` A well connected multifunctional green network..’
• Design guideline 1 – ‘Multifunctional gGreen networks should…’
• Design guideline 2 - ‘…design of the multifunctional green network…’
• Design guideline 4 – ‘…when designing for a multifunctional green network…’
• Design guideline 5 - `Multifunctional gGreen networks could contain..’
Code 13 Biodiversity
Through ensuring BNG delivers not only benefits for biodiversity, but more widely through the
multifunctionality of GI, BNG can deliver socioeconomic benefits simultaneously. ECC
recommend reference is made to securing net gain in biodiversity rather than simply biodiversity.
In particular, as of 12th February 2024 all major planning applications have a mandatory
requirement to deliver a minimum of 10% BNG consistent with the Environment Act 2021. The
requirement relates to small sites from 2 April 2024.
ECC recommend Design guideline 3 is strengthened to read:
New development proposals should create aim for the creation of new habitats and wildlife
corridors, e.g. by aligning back and front gardens or installing bird boxes or bricks in walls;
Code 14 Water management
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly with regards greenfield and brownfield run off rates, climate change
allowances, water quality, rainwater reuse/harvesting, green spaces and biodiversity.
ECC recommend reference is made to arrangements for SuDS maintenance and their adoption.
It is the LLFA’s preference that the drainage network and its accompanying SuDS features are
adopted by a public body where possible to ensure lifelong maintenance, and any public body
should be engaged early in the design process.
Code 15 Trees
With regards Design guideline 7 - any tree planting within new development will be required to
contribute a commuted sum for maintenance issues associated with street tree planting.
Interested parties should work with highways officers to ensure that the right trees are planted in
the right places, and solutions are found that are compatible with highways standards and the
needs of different users consistent with NPPF, paragraph 136. Reference should be made to the
EDG: Highways Technical Manual - Planting in sight splays.
Code.17 Development layout
With regards Design guideline 3 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
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cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
Code.20 Housing mix
With regards Design guideline 1, ECC recommend reference could be amended to be consistent
with NPPF, paragraph 70b in relation to LPAs being required to promote the development of a
good mix of sites including small sites to come forward for community-led development for
housing and self-build and custom-build housing;
New development should proposed a mix of housing to include a range of house types and
sizes, both developer and community-led development for housing and self-build and custombuild self built, to allow for a variety of options and bring balance to the population profile; and
Code.22 Legibility and wayfinding
ECC welcomes reference in Design guidelines 5 and 6 to providing signage for existing and newly
proposed footpaths and cycle lanes. However, ECC recommend any signage is located so that it
does not impact upon visibility of the highway network and should be consulted as the highway
authority. Local signage may also be progressed through the Colchester Local Highways Panel.
Code.23 Boundary lines, boundary treatments and corner treatment
With regards Design guideline 8, ECC recommend reference to streets being designed to slow
traffic is deleted as this depends on the type of street. The EDG Highways Technical Manual -
Street Type Table (A to H) sets out requirements for different types of street including their
recommended speed limit.
ECC recommend this guideline is amended to be consistent with the necessary change to Code
9, Design guideline 1 to read:
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
Code.25 Hard landscaping, materials and street furniture
With regards Design guideline 3 – please refer to response to Code 15 Trees.
Code 26 Minimising energy use
With regards Design guidelines 8 and 9, ECC recommend reference should be made to new
development being required to have regard to the EDG - Climate Change guidance. This provides
guidance on how to design developments (of all scales and types) to meet the net zero carbon
and energy standards, mitigate potential overheating risk and to address other inter-related
sustainability issues. The aim is to ensure new development mitigates, adapts and is resilient to
a changing climate.
ECC, through the Essex Climate and Planning Unit (CaPU). has recently published a number of
policy and evidence base documents to support emerging Local Plans and the determination of
planning applications to move towards net zero development, which can be viewed here.
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A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Code.28 Minimising construction waste
ECC support reference in paragraph 2 regarding developers being required to prepare a Site
Waste Management Plans. This is consistent with Mineral Local Plan Policy 4 - Reducing the use
of Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.29 Recycling materials and buildings
ECC support this code as it is consistent with Mineral Local Plan Policy 4 - Reducing the use of
Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.30 Electric vehicle charging points
ECC has prepared an Electric Vehicle Charge Point Strategy to deliver `the Right Charger in the
Right Place’ so that by 2030, residents, businesses and visitors in Essex, where car travel is
necessary, will be able to use electric vehicles and be assured there is an accessible, reliable,
easy-to-use, safe and fairly priced charging network. The Strategy will be refreshed by 2025
(Phase 2 Strategy) to look at longer-term private car use and EV uptake. It will explore the supply
of renewable energy to EV charge points and how the conversion of public transport, taxis and
freight vehicles to cleaner fuels can be achieved. Separate strategies will be developed to provide
for alternative clean and zero emission fuels, such as hydrogen.
The Essex Parking Standards – Design and Good Practice (2009) are currently being reviewed
by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They include details
covering electric vehicle charging requirements and standards for both residential and nonresidential uses, including on and off-street locations.
Once these standards have been approved it is expected that they will be a material consideration
to which new development will need to have regard to at an early stage of the design process.
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With regards Off-street car parking, ECC supports the provision of mounted charging points being
integrated into the design of new developments regarding homes. Reference could also be made
to the following requirements for commercial developments.
Commercial developments must provide suitable charging systems for a proportion of the total
number of parking spaces to be provided. Ducting and infrastructure should be in place to
install additional EVCPs when future demand dictates.
Code.31 Storage and slow release
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly the section regarding rainwater re-use, which can be viewed here.
The LLFA expects the management of surface water to follow the drainage hierarchy. With
concern over climate change and increasing risk of water scarcity, re-use of rainwater wherever
possible should be utilised. Therefore, in accordance with the drainage hierarchy contained in
Approved Document H of the Building Regulations, Planning Practice Guidance and the need to
mitigate against water scarcity, all surface water run off must aim to be discharged as high up the
following hierarchy as possible:
▪ Rainwater re-use (rainwater harvesting/greywater recycling)
▪ An adequate soakaway or other infiltration system
▪ Hybrid solution of infiltration and discharging to a surface water body
▪ To a surface water body (e.g. an ordinary watercourse)
▪ To a surface water sewer, highway drain, or other drainage system
▪ To a combined sewer
Code.32 Permeable paving
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 with regards the necessary regulations, standards, and
guidelines relevant to permeable paving and sustainable drainage, and which can be viewed
here.
As the LLFA, for outline applications, preliminary ground investigations, or a desk top study
highlighting the potential capacity for infiltration should be provided. For full applications or where
necessary for discharge of conditions applications, full detailed infiltration testing needs to be
provided in line with BRE365 and the infiltration testing methods found in chapter 25.3 of the
CIRIA SuDS Manual C753. This should include the locations and results. The lowest found rate
should be used as a conservative approach.
4. Delivery
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
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Many references have been made to the EDG in the responses to individual Codes and their
Design guidelines.

Chapter 3 – Vision and Objectives
Neighbourhood Plan Objectives
ECC supports Objective 4 in terms of enhancing the delivery and funding of infrastructure. It is
noted that the plan does not allocate any sites for housing or employment development, therefore
the extent of developer contributions likely to be sought is minimal. However, in order to help any
windfall development that may arise in the plan area, ECC considers reference should be made
to the ECC Developers' Guide for Infrastructure Contributions. This outlines the scope and range
of infrastructure towards which ECC may seek contributions from developers and landowners in
order to make development acceptable in planning terms.
Design codes and guidelines for design landscaping, access and movement and sustainability
Please refer to detailed comments regarding the Great Tey Design Guidelines and Codes (March
2022).
Chapter 4 – Design and Landscaping
Policy GTTEY1: Design
ECC recommend Criterion A also makes reference to new development being required to have
regard to the Essex Design Guide (EDG) as well as the Great Tey Design Guidelines. The EDG
contains a much wider scope, including a Highways Technical Manual; Sustainable Drainage
Systems Design Guide for Essex of which ECC is the statutory and/or Lead Authority; and
sections regarding Ageing Populations and Health and Wellbeing. More recent additions include
Planning for 5G and Solar Farm Guiding Principles.
A. Development should demonstrate high quality design and layout which respects the local
character of Great Tey having regard to identified in the Great Tey Design Guidelines and
Codes and the Essex Design Guide (or any successor documents).
ECC supports reference in Criterion vi. seeking development to `be optimised for energy
efficiency, targeting zero carbon emissions’ and in paragraph 6.3 for buildings to be built to the
highest possible standards to minimise their carbon footprint. ECC notes reference that the
Colchester Local Plan Section 2, Policy DM25 requires development of buildings to incorporate
measures to adapt to and mitigate climate change.
ECC strongly support developments which seek higher requirements for new homes than the
requirement to be in accordance with Building Regulations and go beyond Future Homes
Standard (FHS). ECC, through the Essex Climate and Planning Unit (CaPU). has recently
published a number of policy and evidence base documents to support emerging Local and
Neighbourhood Plans and the determination of planning applications to move towards net zero
development, which can be viewed here.
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
3
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Policy GTTEY2: Landscaping
Chapter 7 - Services, Commerce and Infrastructure
ECC recommend an additional Criterion C is added to the policy to support future proofing digital
connectivity and high-quality mobile coverage for all homes and businesses. It is acknowledged
that new development already has to provide access to high-speed broadband but NPPF,
paragraph 118 requires planning policies to support the expansion of electronic communications
networks, including next generation mobile technology (such as 5G) and full fibre broadband
connections. Policies should set out how high-quality digital infrastructure, providing access to
services from a range of providers, is expected to be delivered and upgraded over time; and
should prioritise full fibre connections to existing and new developments.
In January 2023, amendments were published to the Building Act requiring that new homes are
installed with the fastest broadband connections (gigabit) available within a cost cap. Even where
a gigabit-capable connection is not possible within this cost cap, the new homes will be futureproofed with physical infrastructure to support gigabit-capable connections when they become
available. This is also important given the increase in home working following the pandemic.
The EDG contains supplementary planning guidance for Planning for 5G and can be viewed here
and Planning Guidance for digital connectivity focused on fixed line broadband connections. ECC
has published its Digital Strategy for Essex (2022) which seeks to further expand digital
infrastructure and technologies.
ECC recommend an additional criterion to read:
Proposals for new developments or expansion of existing properties should be capable of
receiving gigabit speed and reliable mobile and broadband connectivity. Proposals will be
supported where the appropriate cabling and ducting is provided to the premises and linked to
infrastructure networks, enabling the fastest available connections. Where connectivity is not
currently available suitable ducting that can accept superfast broadband, fixed line gigabitcable broadband and/or 5G connectivity should be provided to the public highway or other
suitable location.
Non-Policy Action D: Maintaining Local Infrastructure Services
ECC recommend Non-Policy Action D is reviewed as it appears to refer to local infrastructure as
well as more nationally significant infrastructure, namely the Norwich to Tilbury NSIP project, as
outlined in paragraph 7.6.
ECC recommend that Action D only refers to local infrastructure that may arise from any new
development in the Plan area. For the purposes of this Action the widest reasonable definition of
infrastructure and infrastructure providers could be applied and set out in the supporting text.
The term infrastructure can include any structure, building, system facility and/or provision
required by an area for its social and/or economic function and/or wellbeing including (but not
exclusively): footways, cycleways, bridleways and highways; public transport; drainage, SuDs
and flood protection; waste recycling facilities; education and childcare; healthcare; sports,
leisure and recreation facilities; community and social facilities; cultural facilities, including
public art; emergency services; green infrastructure; open space; affordable housing; live/work
units and lifetime homes; broadband; and facilities for specific sections of the community such
as youth or the elderly.
4
In addition, ECC seek reference is made to the ECC Developers' Guide for Infrastructure
Contributions, which outlines the scope and range of infrastructure towards which ECC may seek
contributions from developers and landowners in order to make development acceptable in
planning terms.
5
Great Tey Design Guidelines and Codes (March 2022)
3.3 General principles and guidelines
ECC recommend design principle 2 should also refer to the `setting’ of heritage assets consistent
with NPPF, paragraph 201.
3.4 General design guidelines and codes
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
Code 2 Development affecting listed and unlisted heritage assets
With regards Design guideline 2, ECC recommend reference should also be made to the `setting’
of heritage assets consistent with NPPF, paragraph 201.
New development proposals should not be visually intrusive or block key views to and from
heritage assets and their setting, as shown in F.2. T
Code.3 Set in rural landscape/ development edges
With regards Design guideline 2, ECC supports new development conserving existing native trees
along lanes but consideration needs to be given to any impact on highway safety and visibility
splays. Detailed guidance is provided in the EDG - Highways Technical Manual - planting in sight
splays..
With regards Design guideline 7, ECC supports the principle of green corridors providing
additional pedestrian and cycle links. Please see comments to Code 8 with regards establishing
multifunctional greenways and their design requirements, namely to be consistent with Cycling
infrastructure design (LTN 1/20).
Code.4 Patterns of growth within the rural landscape
With regards Design guideline 2, ECC recommend reference is made to the need for new
development to also consider the `setting’ of heritage assets consistent with NPPF, paragraph
201.
New development in close proximity to designated and non-designated heritage assets and
their setting must propose green screenings to mitigate any unpleasant visual impact, while
also preserving key views;
With regards Design guideline 7, ECC recommends reference is also made to the need to
maintain safety along any lane for all users (pedestrians, cyclists, horseriders and vehicles). ECC
also recommend `increase’ is replaced by `impact’.
Any proposal that would adversely affect the physical appearance of a rural lane, or give rise
to an unacceptable impact increase on in the amount of traffic, noise, safety or disturbance
arising from traffic must be avoided.
6
With regards Design guideline 8, ECC recommends reference is made to the multifunctional
green network strategy.
`… is encouraged to form part of the multifunctional green network strategy (no.4); and
With regards Design guideline 9, ECC recommend any signage is located so that it does not
impact upon visibility of the highway network and should be consulted as the highway authority.
All requests for signs need to comply with Traffic Signs Regulations and General Directions 2016
and other ECC policies. Any scheme investigation will also consider street clutter, available
highway land and relationship to any utility equipment. Usually the appropriate signs are identified
when a development is agreed and the impact of traffic on the wider network is assessed. Local
signage may also be progressed through the Colchester Local Highways Panel.
Code 7 Accessible and attractive footpath network/ access to the countryside
ECC recommend the correct terminology is consistently used with regards the terms ‘footpaths’
and ‘footways’ throughout the document. For example, pavements beside public roads are not
public footpaths and are better referenced as footways. Public footpaths are shown on definitive
maps recording Public Rights of Way where anyone has the legal right to use on foot.
ECC recommend the title is amended to refer to `footway and footpath’ network.
ECC suggest the following clarifications on this matter:
• Design guideline 1 – amend `footpaths’ to `footways’ as these relate to more urban streets
than Public Rights of Way (PRoW)
• Design guideline 2 - reference to `multifunctional’ should be included to read:
Where possible, new proposed footpaths should link up green spaces and woodlands to
create a network of multifunctional green walking routes and promote biodiversity. For
example, the Strategic Wildlife Corridors, as shown in F.44, could include footpath
connections and other green links that could connect new development and form part of
an a multifunctional integrated green infrastructure network;
• Design guideline 4 – reference should be made to new signposts being located so that it
does not impact upon visibility of the highway network and any proposals should be
considered by the highway authority. Please refer to comments regarding Code 4,
Guideline 7.
• Design guideline 5 – amend to `footpath’ to ‘footway’’
Code 8 Prioritise walking and cycling
ECC suggest the following clarifications on this matter:
• Paragraph 1 – refer to `There is an extensive network of footways and footpaths public
footpaths and rights of way in the parish.’
• Design guideline 2 – amend `favour’ to `prioritise’ to be consistent with the Code 8 title,
Design guideline 4 and the new Highway Code. The latter states that drivers must be
aware that pedestrians, cyclists, horse riders, carriage drivers and motorcyclists, as the
most vulnerable road users, should take priority over cars.
• Design guideline 2,3 and 4 – replace `footpath’ with `footway’.
Code 9 People-friendly streets and green links
ECC welcomes the requirement for new footpaths/footways to link up with green and blue
infrastructure to create a network of green walking routes and promote biodiversity. ECC
7
recommend reference is made to establishing `multifunctional greenways’ to promote sustainable
and active travel movements and contribute to health and wellbeing.
ECC welcomes the aim to prioritise walking and cycling to help get people healthier and to gain
access with nature. ECC support the principle of establishing multifunctional greenways to
promote sustainable and active travel movements and contribute to health and wellbeing. Any
design of new routes will be required to be consistent with Cycling infrastructure design (LTN
1/20) and to be coherent (allow people to reach day to day destinations easily); direct, safe,
comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
Any pedestrian and cycle links being bordered with rich vegetation and trees should require
consultation with the highway authority given the potential danger to pedestrians and cyclists of
overhanging hedges as well as any impact on highway safety and visibility splays. Detailed
guidance is provided in the EDG - Highways Technical Manual - planting in sight splays. ECC
seeks to be consulted upon any relevant tree planting in proximity to the highway, walking and
cycling routes where the future height, breadth and root growth may impact upon user safety.
ECC recommend design guideline 1 is amended requiring street design being required to have
regard to the standards set out in the EDG - Highways Technical Manual. The prioritisation of
vulnerable users is also consistent with the Highway Code (see response to Code 8)
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
With regards Design guideline 2, ECC recommend reference to`streets should not be built to
maximise vehicle speed or capacity’ should be deleted and replaced with reference to the EDG
Highways Technical Manual - Street Type Table (A to H) in terms of the type of street and
recommended speed limit.
Within the development boundaries, streets should be constructed consistent with their street
type and speed limit, having regard to the EDG Highways Technical Manual - Street Type
Table (A to H) in not be built to maximise vehicle speed or capacity. A range of traffic calming
measures could be introduced by design
With regards Design guideline 4 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
With regards Design guideline 5 – ECC considers reference is made to multifunctional green
infrastructure, as they promote sustainable and active travel movements, contribute to health and
wellbeing, and can be incorporated within sustainable drainage measures (consistent with Code
12, Design principle 2).
Streets must respect the existing vegetation, while also incorporating new opportunities for
landscaping, multifunctional green infrastructure, which may incorporate and sustainable
drainage measures; and
With regards Design guideline 6 – ECC recommend the access street dimensions (page 35);
residential street key dimensions (page 37)and edge lanes key dimension (page 39) should be
reviewed against the EDG Highways Technical Manual - Street Type Table (A to H) for
consistency.
8
Reference should be made to the provision of bus stops, where appropriate, which must provide
seating and shelter, raised kerb, ancillary infrastructure, real time information (where appropriate)
and be designed in keeping with the character of the local area. Further guidance is provided in
the EDG and can be found here.
Code 10 Parking and servicing
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They have
been subject to two consultations with LPAs and developers. The standards are being revised to
reflect changes in the new Use Class Orders and national planning policy. Different standards
are required in different areas based on levels of accessibility, namely town centres (highly
accessible); rural (poorly accessible); and other areas (moderately accessible). Details also cover
electric vehicle charging requirements for both residential and non-residential uses. More detailed
design guidance is also provided for both residential and commercial cycle parking taking account
of LTN 1/20 guidance.
With regards Design guideline 1 – please see comments to Code 15 Trees.
With regards Design guideline 4, ECC welcome the reference to the need to be able to charge
electric vehicles. Please se comments under Code.30 Electric vehicle charging points.
Code 11 Cycle parking
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. More
detailed design guidance is also provided for both residential and commercial cycle parking taking
account of LTN 1/20 guidance.
With regards Design guideline 3 – Houses without garages, the emerging parking standards state
that any external access to a location where bicycles can be stored should enable cycles not to
be wheeled through the house, preferably within the property boundary, as opposed to shared
facilities. The bike storage should be covered, secure and large enough to house the number of
bikes/spaces required in line with the standards for that type of use. The emerging standards
require a door width of at least 1.0m should be provided upon access to storage facilities when
provided within the footprint of the dwelling or as a freestanding shed. In flatted developments the
cycle store should be incorporated within the building but accessed directly from the outside with
a minimum recommended door width of 1.2m.
ECC recommend the following amendment and to Figure 33.
When provided within the footprint of the dwelling or as a free standing shed, cycle parking
should be accessed by means of a door at least 1.0m 900mm and the structure should be at
least 2m deep; and
With regards Design guideline 1 – Houses with garages – reference is made to minimum garage
size being 7m x 3m to allow space for cycle storage. This is consistent with the emerging parking
standards dimensions, which includes space for storage and cycle parking.
Code 12 Create a green network
9
ECC seek clarification as to whether this section will be reviewed to take account of the published
National Green Infrastructure Framework (2023) and the Essex Green Infrastructure Strategy
(2020) and the Essex Green Infrastructure Standards (June 2022).
ECC support the principle of establishing multifunctional greenways to promote sustainable and
active travel movements, contribute to health and wellbeing and increase opportunities for access
to nature. Any design of new routes will be required to be consistent with Cycling infrastructure
design (LTN 1/20) and to be coherent (allow people to reach day to day destinations easily);
direct, safe, comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
The title should be amended to refer to `multifunctional green network’ with similar references in:
• Paragraph 1 - ` A well connected multifunctional green network..’
• Design guideline 1 – ‘Multifunctional gGreen networks should…’
• Design guideline 2 - ‘…design of the multifunctional green network…’
• Design guideline 4 – ‘…when designing for a multifunctional green network…’
• Design guideline 5 - `Multifunctional gGreen networks could contain..’
Code 13 Biodiversity
Through ensuring BNG delivers not only benefits for biodiversity, but more widely through the
multifunctionality of GI, BNG can deliver socioeconomic benefits simultaneously. ECC
recommend reference is made to securing net gain in biodiversity rather than simply biodiversity.
In particular, as of 12th February 2024 all major planning applications have a mandatory
requirement to deliver a minimum of 10% BNG consistent with the Environment Act 2021. The
requirement relates to small sites from 2 April 2024.
ECC recommend Design guideline 3 is strengthened to read:
New development proposals should create aim for the creation of new habitats and wildlife
corridors, e.g. by aligning back and front gardens or installing bird boxes or bricks in walls;
Code 14 Water management
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly with regards greenfield and brownfield run off rates, climate change
allowances, water quality, rainwater reuse/harvesting, green spaces and biodiversity.
ECC recommend reference is made to arrangements for SuDS maintenance and their adoption.
It is the LLFA’s preference that the drainage network and its accompanying SuDS features are
adopted by a public body where possible to ensure lifelong maintenance, and any public body
should be engaged early in the design process.
Code 15 Trees
With regards Design guideline 7 - any tree planting within new development will be required to
contribute a commuted sum for maintenance issues associated with street tree planting.
Interested parties should work with highways officers to ensure that the right trees are planted in
the right places, and solutions are found that are compatible with highways standards and the
needs of different users consistent with NPPF, paragraph 136. Reference should be made to the
EDG: Highways Technical Manual - Planting in sight splays.
Code.17 Development layout
With regards Design guideline 3 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
10
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
Code.20 Housing mix
With regards Design guideline 1, ECC recommend reference could be amended to be consistent
with NPPF, paragraph 70b in relation to LPAs being required to promote the development of a
good mix of sites including small sites to come forward for community-led development for
housing and self-build and custom-build housing;
New development should proposed a mix of housing to include a range of house types and
sizes, both developer and community-led development for housing and self-build and custombuild self built, to allow for a variety of options and bring balance to the population profile; and
Code.22 Legibility and wayfinding
ECC welcomes reference in Design guidelines 5 and 6 to providing signage for existing and newly
proposed footpaths and cycle lanes. However, ECC recommend any signage is located so that it
does not impact upon visibility of the highway network and should be consulted as the highway
authority. Local signage may also be progressed through the Colchester Local Highways Panel.
Code.23 Boundary lines, boundary treatments and corner treatment
With regards Design guideline 8, ECC recommend reference to streets being designed to slow
traffic is deleted as this depends on the type of street. The EDG Highways Technical Manual -
Street Type Table (A to H) sets out requirements for different types of street including their
recommended speed limit.
ECC recommend this guideline is amended to be consistent with the necessary change to Code
9, Design guideline 1 to read:
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
Code.25 Hard landscaping, materials and street furniture
With regards Design guideline 3 – please refer to response to Code 15 Trees.
Code 26 Minimising energy use
With regards Design guidelines 8 and 9, ECC recommend reference should be made to new
development being required to have regard to the EDG - Climate Change guidance. This provides
guidance on how to design developments (of all scales and types) to meet the net zero carbon
and energy standards, mitigate potential overheating risk and to address other inter-related
sustainability issues. The aim is to ensure new development mitigates, adapts and is resilient to
a changing climate.
ECC, through the Essex Climate and Planning Unit (CaPU). has recently published a number of
policy and evidence base documents to support emerging Local Plans and the determination of
planning applications to move towards net zero development, which can be viewed here.
11
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Code.28 Minimising construction waste
ECC support reference in paragraph 2 regarding developers being required to prepare a Site
Waste Management Plans. This is consistent with Mineral Local Plan Policy 4 - Reducing the use
of Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.29 Recycling materials and buildings
ECC support this code as it is consistent with Mineral Local Plan Policy 4 - Reducing the use of
Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.30 Electric vehicle charging points
ECC has prepared an Electric Vehicle Charge Point Strategy to deliver `the Right Charger in the
Right Place’ so that by 2030, residents, businesses and visitors in Essex, where car travel is
necessary, will be able to use electric vehicles and be assured there is an accessible, reliable,
easy-to-use, safe and fairly priced charging network. The Strategy will be refreshed by 2025
(Phase 2 Strategy) to look at longer-term private car use and EV uptake. It will explore the supply
of renewable energy to EV charge points and how the conversion of public transport, taxis and
freight vehicles to cleaner fuels can be achieved. Separate strategies will be developed to provide
for alternative clean and zero emission fuels, such as hydrogen.
The Essex Parking Standards – Design and Good Practice (2009) are currently being reviewed
by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They include details
covering electric vehicle charging requirements and standards for both residential and nonresidential uses, including on and off-street locations.
Once these standards have been approved it is expected that they will be a material consideration
to which new development will need to have regard to at an early stage of the design process.
12
With regards Off-street car parking, ECC supports the provision of mounted charging points being
integrated into the design of new developments regarding homes. Reference could also be made
to the following requirements for commercial developments.
Commercial developments must provide suitable charging systems for a proportion of the total
number of parking spaces to be provided. Ducting and infrastructure should be in place to
install additional EVCPs when future demand dictates.
Code.31 Storage and slow release
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly the section regarding rainwater re-use, which can be viewed here.
The LLFA expects the management of surface water to follow the drainage hierarchy. With
concern over climate change and increasing risk of water scarcity, re-use of rainwater wherever
possible should be utilised. Therefore, in accordance with the drainage hierarchy contained in
Approved Document H of the Building Regulations, Planning Practice Guidance and the need to
mitigate against water scarcity, all surface water run off must aim to be discharged as high up the
following hierarchy as possible:
▪ Rainwater re-use (rainwater harvesting/greywater recycling)
▪ An adequate soakaway or other infiltration system
▪ Hybrid solution of infiltration and discharging to a surface water body
▪ To a surface water body (e.g. an ordinary watercourse)
▪ To a surface water sewer, highway drain, or other drainage system
▪ To a combined sewer
Code.32 Permeable paving
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 with regards the necessary regulations, standards, and
guidelines relevant to permeable paving and sustainable drainage, and which can be viewed
here.
As the LLFA, for outline applications, preliminary ground investigations, or a desk top study
highlighting the potential capacity for infiltration should be provided. For full applications or where
necessary for discharge of conditions applications, full detailed infiltration testing needs to be
provided in line with BRE365 and the infiltration testing methods found in chapter 25.3 of the
CIRIA SuDS Manual C753. This should include the locations and results. The lowest found rate
should be used as a conservative approach.
4. Delivery
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
13
Many references have been made to the EDG in the responses to individual Codes and their
Design guidelines.

Chapter 3 – Vision and Objectives
Neighbourhood Plan Objectives
ECC supports Objective 4 in terms of enhancing the delivery and funding of infrastructure. It is
noted that the plan does not allocate any sites for housing or employment development, therefore
the extent of developer contributions likely to be sought is minimal. However, in order to help any
windfall development that may arise in the plan area, ECC considers reference should be made
to the ECC Developers' Guide for Infrastructure Contributions. This outlines the scope and range
of infrastructure towards which ECC may seek contributions from developers and landowners in
order to make development acceptable in planning terms.
Design codes and guidelines for design landscaping, access and movement and sustainability
Please refer to detailed comments regarding the Great Tey Design Guidelines and Codes (March
2022).
Chapter 4 – Design and Landscaping
Policy GTTEY1: Design
ECC recommend Criterion A also makes reference to new development being required to have
regard to the Essex Design Guide (EDG) as well as the Great Tey Design Guidelines. The EDG
contains a much wider scope, including a Highways Technical Manual; Sustainable Drainage
Systems Design Guide for Essex of which ECC is the statutory and/or Lead Authority; and
sections regarding Ageing Populations and Health and Wellbeing. More recent additions include
Planning for 5G and Solar Farm Guiding Principles.
A. Development should demonstrate high quality design and layout which respects the local
character of Great Tey having regard to identified in the Great Tey Design Guidelines and
Codes and the Essex Design Guide (or any successor documents).
ECC supports reference in Criterion vi. seeking development to `be optimised for energy
efficiency, targeting zero carbon emissions’ and in paragraph 6.3 for buildings to be built to the
highest possible standards to minimise their carbon footprint. ECC notes reference that the
Colchester Local Plan Section 2, Policy DM25 requires development of buildings to incorporate
measures to adapt to and mitigate climate change.
ECC strongly support developments which seek higher requirements for new homes than the
requirement to be in accordance with Building Regulations and go beyond Future Homes
Standard (FHS). ECC, through the Essex Climate and Planning Unit (CaPU). has recently
published a number of policy and evidence base documents to support emerging Local and
Neighbourhood Plans and the determination of planning applications to move towards net zero
development, which can be viewed here.
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
3
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Policy GTTEY2: Landscaping
Chapter 7 - Services, Commerce and Infrastructure
ECC recommend an additional Criterion C is added to the policy to support future proofing digital
connectivity and high-quality mobile coverage for all homes and businesses. It is acknowledged
that new development already has to provide access to high-speed broadband but NPPF,
paragraph 118 requires planning policies to support the expansion of electronic communications
networks, including next generation mobile technology (such as 5G) and full fibre broadband
connections. Policies should set out how high-quality digital infrastructure, providing access to
services from a range of providers, is expected to be delivered and upgraded over time; and
should prioritise full fibre connections to existing and new developments.
In January 2023, amendments were published to the Building Act requiring that new homes are
installed with the fastest broadband connections (gigabit) available within a cost cap. Even where
a gigabit-capable connection is not possible within this cost cap, the new homes will be futureproofed with physical infrastructure to support gigabit-capable connections when they become
available. This is also important given the increase in home working following the pandemic.
The EDG contains supplementary planning guidance for Planning for 5G and can be viewed here
and Planning Guidance for digital connectivity focused on fixed line broadband connections. ECC
has published its Digital Strategy for Essex (2022) which seeks to further expand digital
infrastructure and technologies.
ECC recommend an additional criterion to read:
Proposals for new developments or expansion of existing properties should be capable of
receiving gigabit speed and reliable mobile and broadband connectivity. Proposals will be
supported where the appropriate cabling and ducting is provided to the premises and linked to
infrastructure networks, enabling the fastest available connections. Where connectivity is not
currently available suitable ducting that can accept superfast broadband, fixed line gigabitcable broadband and/or 5G connectivity should be provided to the public highway or other
suitable location.
Non-Policy Action D: Maintaining Local Infrastructure Services
ECC recommend Non-Policy Action D is reviewed as it appears to refer to local infrastructure as
well as more nationally significant infrastructure, namely the Norwich to Tilbury NSIP project, as
outlined in paragraph 7.6.
ECC recommend that Action D only refers to local infrastructure that may arise from any new
development in the Plan area. For the purposes of this Action the widest reasonable definition of
infrastructure and infrastructure providers could be applied and set out in the supporting text.
The term infrastructure can include any structure, building, system facility and/or provision
required by an area for its social and/or economic function and/or wellbeing including (but not
exclusively): footways, cycleways, bridleways and highways; public transport; drainage, SuDs
and flood protection; waste recycling facilities; education and childcare; healthcare; sports,
leisure and recreation facilities; community and social facilities; cultural facilities, including
public art; emergency services; green infrastructure; open space; affordable housing; live/work
units and lifetime homes; broadband; and facilities for specific sections of the community such
as youth or the elderly.
4
In addition, ECC seek reference is made to the ECC Developers' Guide for Infrastructure
Contributions, which outlines the scope and range of infrastructure towards which ECC may seek
contributions from developers and landowners in order to make development acceptable in
planning terms.
5
Great Tey Design Guidelines and Codes (March 2022)
3.3 General principles and guidelines
ECC recommend design principle 2 should also refer to the `setting’ of heritage assets consistent
with NPPF, paragraph 201.
3.4 General design guidelines and codes
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
Code 2 Development affecting listed and unlisted heritage assets
With regards Design guideline 2, ECC recommend reference should also be made to the `setting’
of heritage assets consistent with NPPF, paragraph 201.
New development proposals should not be visually intrusive or block key views to and from
heritage assets and their setting, as shown in F.2. T
Code.3 Set in rural landscape/ development edges
With regards Design guideline 2, ECC supports new development conserving existing native trees
along lanes but consideration needs to be given to any impact on highway safety and visibility
splays. Detailed guidance is provided in the EDG - Highways Technical Manual - planting in sight
splays..
With regards Design guideline 7, ECC supports the principle of green corridors providing
additional pedestrian and cycle links. Please see comments to Code 8 with regards establishing
multifunctional greenways and their design requirements, namely to be consistent with Cycling
infrastructure design (LTN 1/20).
Code.4 Patterns of growth within the rural landscape
With regards Design guideline 2, ECC recommend reference is made to the need for new
development to also consider the `setting’ of heritage assets consistent with NPPF, paragraph
201.
New development in close proximity to designated and non-designated heritage assets and
their setting must propose green screenings to mitigate any unpleasant visual impact, while
also preserving key views;
With regards Design guideline 7, ECC recommends reference is also made to the need to
maintain safety along any lane for all users (pedestrians, cyclists, horseriders and vehicles). ECC
also recommend `increase’ is replaced by `impact’.
Any proposal that would adversely affect the physical appearance of a rural lane, or give rise
to an unacceptable impact increase on in the amount of traffic, noise, safety or disturbance
arising from traffic must be avoided.
6
With regards Design guideline 8, ECC recommends reference is made to the multifunctional
green network strategy.
`… is encouraged to form part of the multifunctional green network strategy (no.4); and
With regards Design guideline 9, ECC recommend any signage is located so that it does not
impact upon visibility of the highway network and should be consulted as the highway authority.
All requests for signs need to comply with Traffic Signs Regulations and General Directions 2016
and other ECC policies. Any scheme investigation will also consider street clutter, available
highway land and relationship to any utility equipment. Usually the appropriate signs are identified
when a development is agreed and the impact of traffic on the wider network is assessed. Local
signage may also be progressed through the Colchester Local Highways Panel.
Code 7 Accessible and attractive footpath network/ access to the countryside
ECC recommend the correct terminology is consistently used with regards the terms ‘footpaths’
and ‘footways’ throughout the document. For example, pavements beside public roads are not
public footpaths and are better referenced as footways. Public footpaths are shown on definitive
maps recording Public Rights of Way where anyone has the legal right to use on foot.
ECC recommend the title is amended to refer to `footway and footpath’ network.
ECC suggest the following clarifications on this matter:
• Design guideline 1 – amend `footpaths’ to `footways’ as these relate to more urban streets
than Public Rights of Way (PRoW)
• Design guideline 2 - reference to `multifunctional’ should be included to read:
Where possible, new proposed footpaths should link up green spaces and woodlands to
create a network of multifunctional green walking routes and promote biodiversity. For
example, the Strategic Wildlife Corridors, as shown in F.44, could include footpath
connections and other green links that could connect new development and form part of
an a multifunctional integrated green infrastructure network;
• Design guideline 4 – reference should be made to new signposts being located so that it
does not impact upon visibility of the highway network and any proposals should be
considered by the highway authority. Please refer to comments regarding Code 4,
Guideline 7.
• Design guideline 5 – amend to `footpath’ to ‘footway’’
Code 8 Prioritise walking and cycling
ECC suggest the following clarifications on this matter:
• Paragraph 1 – refer to `There is an extensive network of footways and footpaths public
footpaths and rights of way in the parish.’
• Design guideline 2 – amend `favour’ to `prioritise’ to be consistent with the Code 8 title,
Design guideline 4 and the new Highway Code. The latter states that drivers must be
aware that pedestrians, cyclists, horse riders, carriage drivers and motorcyclists, as the
most vulnerable road users, should take priority over cars.
• Design guideline 2,3 and 4 – replace `footpath’ with `footway’.
Code 9 People-friendly streets and green links
ECC welcomes the requirement for new footpaths/footways to link up with green and blue
infrastructure to create a network of green walking routes and promote biodiversity. ECC
7
recommend reference is made to establishing `multifunctional greenways’ to promote sustainable
and active travel movements and contribute to health and wellbeing.
ECC welcomes the aim to prioritise walking and cycling to help get people healthier and to gain
access with nature. ECC support the principle of establishing multifunctional greenways to
promote sustainable and active travel movements and contribute to health and wellbeing. Any
design of new routes will be required to be consistent with Cycling infrastructure design (LTN
1/20) and to be coherent (allow people to reach day to day destinations easily); direct, safe,
comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
Any pedestrian and cycle links being bordered with rich vegetation and trees should require
consultation with the highway authority given the potential danger to pedestrians and cyclists of
overhanging hedges as well as any impact on highway safety and visibility splays. Detailed
guidance is provided in the EDG - Highways Technical Manual - planting in sight splays. ECC
seeks to be consulted upon any relevant tree planting in proximity to the highway, walking and
cycling routes where the future height, breadth and root growth may impact upon user safety.
ECC recommend design guideline 1 is amended requiring street design being required to have
regard to the standards set out in the EDG - Highways Technical Manual. The prioritisation of
vulnerable users is also consistent with the Highway Code (see response to Code 8)
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
With regards Design guideline 2, ECC recommend reference to`streets should not be built to
maximise vehicle speed or capacity’ should be deleted and replaced with reference to the EDG
Highways Technical Manual - Street Type Table (A to H) in terms of the type of street and
recommended speed limit.
Within the development boundaries, streets should be constructed consistent with their street
type and speed limit, having regard to the EDG Highways Technical Manual - Street Type
Table (A to H) in not be built to maximise vehicle speed or capacity. A range of traffic calming
measures could be introduced by design
With regards Design guideline 4 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
With regards Design guideline 5 – ECC considers reference is made to multifunctional green
infrastructure, as they promote sustainable and active travel movements, contribute to health and
wellbeing, and can be incorporated within sustainable drainage measures (consistent with Code
12, Design principle 2).
Streets must respect the existing vegetation, while also incorporating new opportunities for
landscaping, multifunctional green infrastructure, which may incorporate and sustainable
drainage measures; and
With regards Design guideline 6 – ECC recommend the access street dimensions (page 35);
residential street key dimensions (page 37)and edge lanes key dimension (page 39) should be
reviewed against the EDG Highways Technical Manual - Street Type Table (A to H) for
consistency.
8
Reference should be made to the provision of bus stops, where appropriate, which must provide
seating and shelter, raised kerb, ancillary infrastructure, real time information (where appropriate)
and be designed in keeping with the character of the local area. Further guidance is provided in
the EDG and can be found here.
Code 10 Parking and servicing
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They have
been subject to two consultations with LPAs and developers. The standards are being revised to
reflect changes in the new Use Class Orders and national planning policy. Different standards
are required in different areas based on levels of accessibility, namely town centres (highly
accessible); rural (poorly accessible); and other areas (moderately accessible). Details also cover
electric vehicle charging requirements for both residential and non-residential uses. More detailed
design guidance is also provided for both residential and commercial cycle parking taking account
of LTN 1/20 guidance.
With regards Design guideline 1 – please see comments to Code 15 Trees.
With regards Design guideline 4, ECC welcome the reference to the need to be able to charge
electric vehicles. Please se comments under Code.30 Electric vehicle charging points.
Code 11 Cycle parking
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. More
detailed design guidance is also provided for both residential and commercial cycle parking taking
account of LTN 1/20 guidance.
With regards Design guideline 3 – Houses without garages, the emerging parking standards state
that any external access to a location where bicycles can be stored should enable cycles not to
be wheeled through the house, preferably within the property boundary, as opposed to shared
facilities. The bike storage should be covered, secure and large enough to house the number of
bikes/spaces required in line with the standards for that type of use. The emerging standards
require a door width of at least 1.0m should be provided upon access to storage facilities when
provided within the footprint of the dwelling or as a freestanding shed. In flatted developments the
cycle store should be incorporated within the building but accessed directly from the outside with
a minimum recommended door width of 1.2m.
ECC recommend the following amendment and to Figure 33.
When provided within the footprint of the dwelling or as a free standing shed, cycle parking
should be accessed by means of a door at least 1.0m 900mm and the structure should be at
least 2m deep; and
With regards Design guideline 1 – Houses with garages – reference is made to minimum garage
size being 7m x 3m to allow space for cycle storage. This is consistent with the emerging parking
standards dimensions, which includes space for storage and cycle parking.
Code 12 Create a green network
9
ECC seek clarification as to whether this section will be reviewed to take account of the published
National Green Infrastructure Framework (2023) and the Essex Green Infrastructure Strategy
(2020) and the Essex Green Infrastructure Standards (June 2022).
ECC support the principle of establishing multifunctional greenways to promote sustainable and
active travel movements, contribute to health and wellbeing and increase opportunities for access
to nature. Any design of new routes will be required to be consistent with Cycling infrastructure
design (LTN 1/20) and to be coherent (allow people to reach day to day destinations easily);
direct, safe, comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
The title should be amended to refer to `multifunctional green network’ with similar references in:
• Paragraph 1 - ` A well connected multifunctional green network..’
• Design guideline 1 – ‘Multifunctional gGreen networks should…’
• Design guideline 2 - ‘…design of the multifunctional green network…’
• Design guideline 4 – ‘…when designing for a multifunctional green network…’
• Design guideline 5 - `Multifunctional gGreen networks could contain..’
Code 13 Biodiversity
Through ensuring BNG delivers not only benefits for biodiversity, but more widely through the
multifunctionality of GI, BNG can deliver socioeconomic benefits simultaneously. ECC
recommend reference is made to securing net gain in biodiversity rather than simply biodiversity.
In particular, as of 12th February 2024 all major planning applications have a mandatory
requirement to deliver a minimum of 10% BNG consistent with the Environment Act 2021. The
requirement relates to small sites from 2 April 2024.
ECC recommend Design guideline 3 is strengthened to read:
New development proposals should create aim for the creation of new habitats and wildlife
corridors, e.g. by aligning back and front gardens or installing bird boxes or bricks in walls;
Code 14 Water management
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly with regards greenfield and brownfield run off rates, climate change
allowances, water quality, rainwater reuse/harvesting, green spaces and biodiversity.
ECC recommend reference is made to arrangements for SuDS maintenance and their adoption.
It is the LLFA’s preference that the drainage network and its accompanying SuDS features are
adopted by a public body where possible to ensure lifelong maintenance, and any public body
should be engaged early in the design process.
Code 15 Trees
With regards Design guideline 7 - any tree planting within new development will be required to
contribute a commuted sum for maintenance issues associated with street tree planting.
Interested parties should work with highways officers to ensure that the right trees are planted in
the right places, and solutions are found that are compatible with highways standards and the
needs of different users consistent with NPPF, paragraph 136. Reference should be made to the
EDG: Highways Technical Manual - Planting in sight splays.
Code.17 Development layout
With regards Design guideline 3 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
10
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
Code.20 Housing mix
With regards Design guideline 1, ECC recommend reference could be amended to be consistent
with NPPF, paragraph 70b in relation to LPAs being required to promote the development of a
good mix of sites including small sites to come forward for community-led development for
housing and self-build and custom-build housing;
New development should proposed a mix of housing to include a range of house types and
sizes, both developer and community-led development for housing and self-build and custombuild self built, to allow for a variety of options and bring balance to the population profile; and
Code.22 Legibility and wayfinding
ECC welcomes reference in Design guidelines 5 and 6 to providing signage for existing and newly
proposed footpaths and cycle lanes. However, ECC recommend any signage is located so that it
does not impact upon visibility of the highway network and should be consulted as the highway
authority. Local signage may also be progressed through the Colchester Local Highways Panel.
Code.23 Boundary lines, boundary treatments and corner treatment
With regards Design guideline 8, ECC recommend reference to streets being designed to slow
traffic is deleted as this depends on the type of street. The EDG Highways Technical Manual -
Street Type Table (A to H) sets out requirements for different types of street including their
recommended speed limit.
ECC recommend this guideline is amended to be consistent with the necessary change to Code
9, Design guideline 1 to read:
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
Code.25 Hard landscaping, materials and street furniture
With regards Design guideline 3 – please refer to response to Code 15 Trees.
Code 26 Minimising energy use
With regards Design guidelines 8 and 9, ECC recommend reference should be made to new
development being required to have regard to the EDG - Climate Change guidance. This provides
guidance on how to design developments (of all scales and types) to meet the net zero carbon
and energy standards, mitigate potential overheating risk and to address other inter-related
sustainability issues. The aim is to ensure new development mitigates, adapts and is resilient to
a changing climate.
ECC, through the Essex Climate and Planning Unit (CaPU). has recently published a number of
policy and evidence base documents to support emerging Local Plans and the determination of
planning applications to move towards net zero development, which can be viewed here.
11
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Code.28 Minimising construction waste
ECC support reference in paragraph 2 regarding developers being required to prepare a Site
Waste Management Plans. This is consistent with Mineral Local Plan Policy 4 - Reducing the use
of Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.29 Recycling materials and buildings
ECC support this code as it is consistent with Mineral Local Plan Policy 4 - Reducing the use of
Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.30 Electric vehicle charging points
ECC has prepared an Electric Vehicle Charge Point Strategy to deliver `the Right Charger in the
Right Place’ so that by 2030, residents, businesses and visitors in Essex, where car travel is
necessary, will be able to use electric vehicles and be assured there is an accessible, reliable,
easy-to-use, safe and fairly priced charging network. The Strategy will be refreshed by 2025
(Phase 2 Strategy) to look at longer-term private car use and EV uptake. It will explore the supply
of renewable energy to EV charge points and how the conversion of public transport, taxis and
freight vehicles to cleaner fuels can be achieved. Separate strategies will be developed to provide
for alternative clean and zero emission fuels, such as hydrogen.
The Essex Parking Standards – Design and Good Practice (2009) are currently being reviewed
by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They include details
covering electric vehicle charging requirements and standards for both residential and nonresidential uses, including on and off-street locations.
Once these standards have been approved it is expected that they will be a material consideration
to which new development will need to have regard to at an early stage of the design process.
12
With regards Off-street car parking, ECC supports the provision of mounted charging points being
integrated into the design of new developments regarding homes. Reference could also be made
to the following requirements for commercial developments.
Commercial developments must provide suitable charging systems for a proportion of the total
number of parking spaces to be provided. Ducting and infrastructure should be in place to
install additional EVCPs when future demand dictates.
Code.31 Storage and slow release
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly the section regarding rainwater re-use, which can be viewed here.
The LLFA expects the management of surface water to follow the drainage hierarchy. With
concern over climate change and increasing risk of water scarcity, re-use of rainwater wherever
possible should be utilised. Therefore, in accordance with the drainage hierarchy contained in
Approved Document H of the Building Regulations, Planning Practice Guidance and the need to
mitigate against water scarcity, all surface water run off must aim to be discharged as high up the
following hierarchy as possible:
▪ Rainwater re-use (rainwater harvesting/greywater recycling)
▪ An adequate soakaway or other infiltration system
▪ Hybrid solution of infiltration and discharging to a surface water body
▪ To a surface water body (e.g. an ordinary watercourse)
▪ To a surface water sewer, highway drain, or other drainage system
▪ To a combined sewer
Code.32 Permeable paving
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 with regards the necessary regulations, standards, and
guidelines relevant to permeable paving and sustainable drainage, and which can be viewed
here.
As the LLFA, for outline applications, preliminary ground investigations, or a desk top study
highlighting the potential capacity for infiltration should be provided. For full applications or where
necessary for discharge of conditions applications, full detailed infiltration testing needs to be
provided in line with BRE365 and the infiltration testing methods found in chapter 25.3 of the
CIRIA SuDS Manual C753. This should include the locations and results. The lowest found rate
should be used as a conservative approach.
4. Delivery
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
13
Many references have been made to the EDG in the responses to individual Codes and their
Design guidelines.

Chapter 3 – Vision and Objectives
Neighbourhood Plan Objectives
ECC supports Objective 4 in terms of enhancing the delivery and funding of infrastructure. It is
noted that the plan does not allocate any sites for housing or employment development, therefore
the extent of developer contributions likely to be sought is minimal. However, in order to help any
windfall development that may arise in the plan area, ECC considers reference should be made
to the ECC Developers' Guide for Infrastructure Contributions. This outlines the scope and range
of infrastructure towards which ECC may seek contributions from developers and landowners in
order to make development acceptable in planning terms.
Design codes and guidelines for design landscaping, access and movement and sustainability
Please refer to detailed comments regarding the Great Tey Design Guidelines and Codes (March
2022).
Chapter 4 – Design and Landscaping
Policy GTTEY1: Design
ECC recommend Criterion A also makes reference to new development being required to have
regard to the Essex Design Guide (EDG) as well as the Great Tey Design Guidelines. The EDG
contains a much wider scope, including a Highways Technical Manual; Sustainable Drainage
Systems Design Guide for Essex of which ECC is the statutory and/or Lead Authority; and
sections regarding Ageing Populations and Health and Wellbeing. More recent additions include
Planning for 5G and Solar Farm Guiding Principles.
A. Development should demonstrate high quality design and layout which respects the local
character of Great Tey having regard to identified in the Great Tey Design Guidelines and
Codes and the Essex Design Guide (or any successor documents).
ECC supports reference in Criterion vi. seeking development to `be optimised for energy
efficiency, targeting zero carbon emissions’ and in paragraph 6.3 for buildings to be built to the
highest possible standards to minimise their carbon footprint. ECC notes reference that the
Colchester Local Plan Section 2, Policy DM25 requires development of buildings to incorporate
measures to adapt to and mitigate climate change.
ECC strongly support developments which seek higher requirements for new homes than the
requirement to be in accordance with Building Regulations and go beyond Future Homes
Standard (FHS). ECC, through the Essex Climate and Planning Unit (CaPU). has recently
published a number of policy and evidence base documents to support emerging Local and
Neighbourhood Plans and the determination of planning applications to move towards net zero
development, which can be viewed here.
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
3
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Policy GTTEY2: Landscaping
Chapter 7 - Services, Commerce and Infrastructure
ECC recommend an additional Criterion C is added to the policy to support future proofing digital
connectivity and high-quality mobile coverage for all homes and businesses. It is acknowledged
that new development already has to provide access to high-speed broadband but NPPF,
paragraph 118 requires planning policies to support the expansion of electronic communications
networks, including next generation mobile technology (such as 5G) and full fibre broadband
connections. Policies should set out how high-quality digital infrastructure, providing access to
services from a range of providers, is expected to be delivered and upgraded over time; and
should prioritise full fibre connections to existing and new developments.
In January 2023, amendments were published to the Building Act requiring that new homes are
installed with the fastest broadband connections (gigabit) available within a cost cap. Even where
a gigabit-capable connection is not possible within this cost cap, the new homes will be futureproofed with physical infrastructure to support gigabit-capable connections when they become
available. This is also important given the increase in home working following the pandemic.
The EDG contains supplementary planning guidance for Planning for 5G and can be viewed here
and Planning Guidance for digital connectivity focused on fixed line broadband connections. ECC
has published its Digital Strategy for Essex (2022) which seeks to further expand digital
infrastructure and technologies.
ECC recommend an additional criterion to read:
Proposals for new developments or expansion of existing properties should be capable of
receiving gigabit speed and reliable mobile and broadband connectivity. Proposals will be
supported where the appropriate cabling and ducting is provided to the premises and linked to
infrastructure networks, enabling the fastest available connections. Where connectivity is not
currently available suitable ducting that can accept superfast broadband, fixed line gigabitcable broadband and/or 5G connectivity should be provided to the public highway or other
suitable location.
Non-Policy Action D: Maintaining Local Infrastructure Services
ECC recommend Non-Policy Action D is reviewed as it appears to refer to local infrastructure as
well as more nationally significant infrastructure, namely the Norwich to Tilbury NSIP project, as
outlined in paragraph 7.6.
ECC recommend that Action D only refers to local infrastructure that may arise from any new
development in the Plan area. For the purposes of this Action the widest reasonable definition of
infrastructure and infrastructure providers could be applied and set out in the supporting text.
The term infrastructure can include any structure, building, system facility and/or provision
required by an area for its social and/or economic function and/or wellbeing including (but not
exclusively): footways, cycleways, bridleways and highways; public transport; drainage, SuDs
and flood protection; waste recycling facilities; education and childcare; healthcare; sports,
leisure and recreation facilities; community and social facilities; cultural facilities, including
public art; emergency services; green infrastructure; open space; affordable housing; live/work
units and lifetime homes; broadband; and facilities for specific sections of the community such
as youth or the elderly.
4
In addition, ECC seek reference is made to the ECC Developers' Guide for Infrastructure
Contributions, which outlines the scope and range of infrastructure towards which ECC may seek
contributions from developers and landowners in order to make development acceptable in
planning terms.
5
Great Tey Design Guidelines and Codes (March 2022)
3.3 General principles and guidelines
ECC recommend design principle 2 should also refer to the `setting’ of heritage assets consistent
with NPPF, paragraph 201.
3.4 General design guidelines and codes
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
Code 2 Development affecting listed and unlisted heritage assets
With regards Design guideline 2, ECC recommend reference should also be made to the `setting’
of heritage assets consistent with NPPF, paragraph 201.
New development proposals should not be visually intrusive or block key views to and from
heritage assets and their setting, as shown in F.2. T
Code.3 Set in rural landscape/ development edges
With regards Design guideline 2, ECC supports new development conserving existing native trees
along lanes but consideration needs to be given to any impact on highway safety and visibility
splays. Detailed guidance is provided in the EDG - Highways Technical Manual - planting in sight
splays..
With regards Design guideline 7, ECC supports the principle of green corridors providing
additional pedestrian and cycle links. Please see comments to Code 8 with regards establishing
multifunctional greenways and their design requirements, namely to be consistent with Cycling
infrastructure design (LTN 1/20).
Code.4 Patterns of growth within the rural landscape
With regards Design guideline 2, ECC recommend reference is made to the need for new
development to also consider the `setting’ of heritage assets consistent with NPPF, paragraph
201.
New development in close proximity to designated and non-designated heritage assets and
their setting must propose green screenings to mitigate any unpleasant visual impact, while
also preserving key views;
With regards Design guideline 7, ECC recommends reference is also made to the need to
maintain safety along any lane for all users (pedestrians, cyclists, horseriders and vehicles). ECC
also recommend `increase’ is replaced by `impact’.
Any proposal that would adversely affect the physical appearance of a rural lane, or give rise
to an unacceptable impact increase on in the amount of traffic, noise, safety or disturbance
arising from traffic must be avoided.
6
With regards Design guideline 8, ECC recommends reference is made to the multifunctional
green network strategy.
`… is encouraged to form part of the multifunctional green network strategy (no.4); and
With regards Design guideline 9, ECC recommend any signage is located so that it does not
impact upon visibility of the highway network and should be consulted as the highway authority.
All requests for signs need to comply with Traffic Signs Regulations and General Directions 2016
and other ECC policies. Any scheme investigation will also consider street clutter, available
highway land and relationship to any utility equipment. Usually the appropriate signs are identified
when a development is agreed and the impact of traffic on the wider network is assessed. Local
signage may also be progressed through the Colchester Local Highways Panel.
Code 7 Accessible and attractive footpath network/ access to the countryside
ECC recommend the correct terminology is consistently used with regards the terms ‘footpaths’
and ‘footways’ throughout the document. For example, pavements beside public roads are not
public footpaths and are better referenced as footways. Public footpaths are shown on definitive
maps recording Public Rights of Way where anyone has the legal right to use on foot.
ECC recommend the title is amended to refer to `footway and footpath’ network.
ECC suggest the following clarifications on this matter:
• Design guideline 1 – amend `footpaths’ to `footways’ as these relate to more urban streets
than Public Rights of Way (PRoW)
• Design guideline 2 - reference to `multifunctional’ should be included to read:
Where possible, new proposed footpaths should link up green spaces and woodlands to
create a network of multifunctional green walking routes and promote biodiversity. For
example, the Strategic Wildlife Corridors, as shown in F.44, could include footpath
connections and other green links that could connect new development and form part of
an a multifunctional integrated green infrastructure network;
• Design guideline 4 – reference should be made to new signposts being located so that it
does not impact upon visibility of the highway network and any proposals should be
considered by the highway authority. Please refer to comments regarding Code 4,
Guideline 7.
• Design guideline 5 – amend to `footpath’ to ‘footway’’
Code 8 Prioritise walking and cycling
ECC suggest the following clarifications on this matter:
• Paragraph 1 – refer to `There is an extensive network of footways and footpaths public
footpaths and rights of way in the parish.’
• Design guideline 2 – amend `favour’ to `prioritise’ to be consistent with the Code 8 title,
Design guideline 4 and the new Highway Code. The latter states that drivers must be
aware that pedestrians, cyclists, horse riders, carriage drivers and motorcyclists, as the
most vulnerable road users, should take priority over cars.
• Design guideline 2,3 and 4 – replace `footpath’ with `footway’.
Code 9 People-friendly streets and green links
ECC welcomes the requirement for new footpaths/footways to link up with green and blue
infrastructure to create a network of green walking routes and promote biodiversity. ECC
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recommend reference is made to establishing `multifunctional greenways’ to promote sustainable
and active travel movements and contribute to health and wellbeing.
ECC welcomes the aim to prioritise walking and cycling to help get people healthier and to gain
access with nature. ECC support the principle of establishing multifunctional greenways to
promote sustainable and active travel movements and contribute to health and wellbeing. Any
design of new routes will be required to be consistent with Cycling infrastructure design (LTN
1/20) and to be coherent (allow people to reach day to day destinations easily); direct, safe,
comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
Any pedestrian and cycle links being bordered with rich vegetation and trees should require
consultation with the highway authority given the potential danger to pedestrians and cyclists of
overhanging hedges as well as any impact on highway safety and visibility splays. Detailed
guidance is provided in the EDG - Highways Technical Manual - planting in sight splays. ECC
seeks to be consulted upon any relevant tree planting in proximity to the highway, walking and
cycling routes where the future height, breadth and root growth may impact upon user safety.
ECC recommend design guideline 1 is amended requiring street design being required to have
regard to the standards set out in the EDG - Highways Technical Manual. The prioritisation of
vulnerable users is also consistent with the Highway Code (see response to Code 8)
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
With regards Design guideline 2, ECC recommend reference to`streets should not be built to
maximise vehicle speed or capacity’ should be deleted and replaced with reference to the EDG
Highways Technical Manual - Street Type Table (A to H) in terms of the type of street and
recommended speed limit.
Within the development boundaries, streets should be constructed consistent with their street
type and speed limit, having regard to the EDG Highways Technical Manual - Street Type
Table (A to H) in not be built to maximise vehicle speed or capacity. A range of traffic calming
measures could be introduced by design
With regards Design guideline 4 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
With regards Design guideline 5 – ECC considers reference is made to multifunctional green
infrastructure, as they promote sustainable and active travel movements, contribute to health and
wellbeing, and can be incorporated within sustainable drainage measures (consistent with Code
12, Design principle 2).
Streets must respect the existing vegetation, while also incorporating new opportunities for
landscaping, multifunctional green infrastructure, which may incorporate and sustainable
drainage measures; and
With regards Design guideline 6 – ECC recommend the access street dimensions (page 35);
residential street key dimensions (page 37)and edge lanes key dimension (page 39) should be
reviewed against the EDG Highways Technical Manual - Street Type Table (A to H) for
consistency.
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Reference should be made to the provision of bus stops, where appropriate, which must provide
seating and shelter, raised kerb, ancillary infrastructure, real time information (where appropriate)
and be designed in keeping with the character of the local area. Further guidance is provided in
the EDG and can be found here.
Code 10 Parking and servicing
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They have
been subject to two consultations with LPAs and developers. The standards are being revised to
reflect changes in the new Use Class Orders and national planning policy. Different standards
are required in different areas based on levels of accessibility, namely town centres (highly
accessible); rural (poorly accessible); and other areas (moderately accessible). Details also cover
electric vehicle charging requirements for both residential and non-residential uses. More detailed
design guidance is also provided for both residential and commercial cycle parking taking account
of LTN 1/20 guidance.
With regards Design guideline 1 – please see comments to Code 15 Trees.
With regards Design guideline 4, ECC welcome the reference to the need to be able to charge
electric vehicles. Please se comments under Code.30 Electric vehicle charging points.
Code 11 Cycle parking
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. More
detailed design guidance is also provided for both residential and commercial cycle parking taking
account of LTN 1/20 guidance.
With regards Design guideline 3 – Houses without garages, the emerging parking standards state
that any external access to a location where bicycles can be stored should enable cycles not to
be wheeled through the house, preferably within the property boundary, as opposed to shared
facilities. The bike storage should be covered, secure and large enough to house the number of
bikes/spaces required in line with the standards for that type of use. The emerging standards
require a door width of at least 1.0m should be provided upon access to storage facilities when
provided within the footprint of the dwelling or as a freestanding shed. In flatted developments the
cycle store should be incorporated within the building but accessed directly from the outside with
a minimum recommended door width of 1.2m.
ECC recommend the following amendment and to Figure 33.
When provided within the footprint of the dwelling or as a free standing shed, cycle parking
should be accessed by means of a door at least 1.0m 900mm and the structure should be at
least 2m deep; and
With regards Design guideline 1 – Houses with garages – reference is made to minimum garage
size being 7m x 3m to allow space for cycle storage. This is consistent with the emerging parking
standards dimensions, which includes space for storage and cycle parking.
Code 12 Create a green network
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ECC seek clarification as to whether this section will be reviewed to take account of the published
National Green Infrastructure Framework (2023) and the Essex Green Infrastructure Strategy
(2020) and the Essex Green Infrastructure Standards (June 2022).
ECC support the principle of establishing multifunctional greenways to promote sustainable and
active travel movements, contribute to health and wellbeing and increase opportunities for access
to nature. Any design of new routes will be required to be consistent with Cycling infrastructure
design (LTN 1/20) and to be coherent (allow people to reach day to day destinations easily);
direct, safe, comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
The title should be amended to refer to `multifunctional green network’ with similar references in:
• Paragraph 1 - ` A well connected multifunctional green network..’
• Design guideline 1 – ‘Multifunctional gGreen networks should…’
• Design guideline 2 - ‘…design of the multifunctional green network…’
• Design guideline 4 – ‘…when designing for a multifunctional green network…’
• Design guideline 5 - `Multifunctional gGreen networks could contain..’
Code 13 Biodiversity
Through ensuring BNG delivers not only benefits for biodiversity, but more widely through the
multifunctionality of GI, BNG can deliver socioeconomic benefits simultaneously. ECC
recommend reference is made to securing net gain in biodiversity rather than simply biodiversity.
In particular, as of 12th February 2024 all major planning applications have a mandatory
requirement to deliver a minimum of 10% BNG consistent with the Environment Act 2021. The
requirement relates to small sites from 2 April 2024.
ECC recommend Design guideline 3 is strengthened to read:
New development proposals should create aim for the creation of new habitats and wildlife
corridors, e.g. by aligning back and front gardens or installing bird boxes or bricks in walls;
Code 14 Water management
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly with regards greenfield and brownfield run off rates, climate change
allowances, water quality, rainwater reuse/harvesting, green spaces and biodiversity.
ECC recommend reference is made to arrangements for SuDS maintenance and their adoption.
It is the LLFA’s preference that the drainage network and its accompanying SuDS features are
adopted by a public body where possible to ensure lifelong maintenance, and any public body
should be engaged early in the design process.
Code 15 Trees
With regards Design guideline 7 - any tree planting within new development will be required to
contribute a commuted sum for maintenance issues associated with street tree planting.
Interested parties should work with highways officers to ensure that the right trees are planted in
the right places, and solutions are found that are compatible with highways standards and the
needs of different users consistent with NPPF, paragraph 136. Reference should be made to the
EDG: Highways Technical Manual - Planting in sight splays.
Code.17 Development layout
With regards Design guideline 3 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
10
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
Code.20 Housing mix
With regards Design guideline 1, ECC recommend reference could be amended to be consistent
with NPPF, paragraph 70b in relation to LPAs being required to promote the development of a
good mix of sites including small sites to come forward for community-led development for
housing and self-build and custom-build housing;
New development should proposed a mix of housing to include a range of house types and
sizes, both developer and community-led development for housing and self-build and custombuild self built, to allow for a variety of options and bring balance to the population profile; and
Code.22 Legibility and wayfinding
ECC welcomes reference in Design guidelines 5 and 6 to providing signage for existing and newly
proposed footpaths and cycle lanes. However, ECC recommend any signage is located so that it
does not impact upon visibility of the highway network and should be consulted as the highway
authority. Local signage may also be progressed through the Colchester Local Highways Panel.
Code.23 Boundary lines, boundary treatments and corner treatment
With regards Design guideline 8, ECC recommend reference to streets being designed to slow
traffic is deleted as this depends on the type of street. The EDG Highways Technical Manual -
Street Type Table (A to H) sets out requirements for different types of street including their
recommended speed limit.
ECC recommend this guideline is amended to be consistent with the necessary change to Code
9, Design guideline 1 to read:
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
Code.25 Hard landscaping, materials and street furniture
With regards Design guideline 3 – please refer to response to Code 15 Trees.
Code 26 Minimising energy use
With regards Design guidelines 8 and 9, ECC recommend reference should be made to new
development being required to have regard to the EDG - Climate Change guidance. This provides
guidance on how to design developments (of all scales and types) to meet the net zero carbon
and energy standards, mitigate potential overheating risk and to address other inter-related
sustainability issues. The aim is to ensure new development mitigates, adapts and is resilient to
a changing climate.
ECC, through the Essex Climate and Planning Unit (CaPU). has recently published a number of
policy and evidence base documents to support emerging Local Plans and the determination of
planning applications to move towards net zero development, which can be viewed here.
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A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Code.28 Minimising construction waste
ECC support reference in paragraph 2 regarding developers being required to prepare a Site
Waste Management Plans. This is consistent with Mineral Local Plan Policy 4 - Reducing the use
of Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.29 Recycling materials and buildings
ECC support this code as it is consistent with Mineral Local Plan Policy 4 - Reducing the use of
Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.30 Electric vehicle charging points
ECC has prepared an Electric Vehicle Charge Point Strategy to deliver `the Right Charger in the
Right Place’ so that by 2030, residents, businesses and visitors in Essex, where car travel is
necessary, will be able to use electric vehicles and be assured there is an accessible, reliable,
easy-to-use, safe and fairly priced charging network. The Strategy will be refreshed by 2025
(Phase 2 Strategy) to look at longer-term private car use and EV uptake. It will explore the supply
of renewable energy to EV charge points and how the conversion of public transport, taxis and
freight vehicles to cleaner fuels can be achieved. Separate strategies will be developed to provide
for alternative clean and zero emission fuels, such as hydrogen.
The Essex Parking Standards – Design and Good Practice (2009) are currently being reviewed
by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They include details
covering electric vehicle charging requirements and standards for both residential and nonresidential uses, including on and off-street locations.
Once these standards have been approved it is expected that they will be a material consideration
to which new development will need to have regard to at an early stage of the design process.
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With regards Off-street car parking, ECC supports the provision of mounted charging points being
integrated into the design of new developments regarding homes. Reference could also be made
to the following requirements for commercial developments.
Commercial developments must provide suitable charging systems for a proportion of the total
number of parking spaces to be provided. Ducting and infrastructure should be in place to
install additional EVCPs when future demand dictates.
Code.31 Storage and slow release
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly the section regarding rainwater re-use, which can be viewed here.
The LLFA expects the management of surface water to follow the drainage hierarchy. With
concern over climate change and increasing risk of water scarcity, re-use of rainwater wherever
possible should be utilised. Therefore, in accordance with the drainage hierarchy contained in
Approved Document H of the Building Regulations, Planning Practice Guidance and the need to
mitigate against water scarcity, all surface water run off must aim to be discharged as high up the
following hierarchy as possible:
▪ Rainwater re-use (rainwater harvesting/greywater recycling)
▪ An adequate soakaway or other infiltration system
▪ Hybrid solution of infiltration and discharging to a surface water body
▪ To a surface water body (e.g. an ordinary watercourse)
▪ To a surface water sewer, highway drain, or other drainage system
▪ To a combined sewer
Code.32 Permeable paving
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 with regards the necessary regulations, standards, and
guidelines relevant to permeable paving and sustainable drainage, and which can be viewed
here.
As the LLFA, for outline applications, preliminary ground investigations, or a desk top study
highlighting the potential capacity for infiltration should be provided. For full applications or where
necessary for discharge of conditions applications, full detailed infiltration testing needs to be
provided in line with BRE365 and the infiltration testing methods found in chapter 25.3 of the
CIRIA SuDS Manual C753. This should include the locations and results. The lowest found rate
should be used as a conservative approach.
4. Delivery
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
13
Many references have been made to the EDG in the responses to individual Codes and their
Design guidelines.

Chapter 3 – Vision and Objectives
Neighbourhood Plan Objectives
ECC supports Objective 4 in terms of enhancing the delivery and funding of infrastructure. It is
noted that the plan does not allocate any sites for housing or employment development, therefore
the extent of developer contributions likely to be sought is minimal. However, in order to help any
windfall development that may arise in the plan area, ECC considers reference should be made
to the ECC Developers' Guide for Infrastructure Contributions. This outlines the scope and range
of infrastructure towards which ECC may seek contributions from developers and landowners in
order to make development acceptable in planning terms.
Design codes and guidelines for design landscaping, access and movement and sustainability
Please refer to detailed comments regarding the Great Tey Design Guidelines and Codes (March
2022).
Chapter 4 – Design and Landscaping
Policy GTTEY1: Design
ECC recommend Criterion A also makes reference to new development being required to have
regard to the Essex Design Guide (EDG) as well as the Great Tey Design Guidelines. The EDG
contains a much wider scope, including a Highways Technical Manual; Sustainable Drainage
Systems Design Guide for Essex of which ECC is the statutory and/or Lead Authority; and
sections regarding Ageing Populations and Health and Wellbeing. More recent additions include
Planning for 5G and Solar Farm Guiding Principles.
A. Development should demonstrate high quality design and layout which respects the local
character of Great Tey having regard to identified in the Great Tey Design Guidelines and
Codes and the Essex Design Guide (or any successor documents).
ECC supports reference in Criterion vi. seeking development to `be optimised for energy
efficiency, targeting zero carbon emissions’ and in paragraph 6.3 for buildings to be built to the
highest possible standards to minimise their carbon footprint. ECC notes reference that the
Colchester Local Plan Section 2, Policy DM25 requires development of buildings to incorporate
measures to adapt to and mitigate climate change.
ECC strongly support developments which seek higher requirements for new homes than the
requirement to be in accordance with Building Regulations and go beyond Future Homes
Standard (FHS). ECC, through the Essex Climate and Planning Unit (CaPU). has recently
published a number of policy and evidence base documents to support emerging Local and
Neighbourhood Plans and the determination of planning applications to move towards net zero
development, which can be viewed here.
A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
3
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Policy GTTEY2: Landscaping
Chapter 7 - Services, Commerce and Infrastructure
ECC recommend an additional Criterion C is added to the policy to support future proofing digital
connectivity and high-quality mobile coverage for all homes and businesses. It is acknowledged
that new development already has to provide access to high-speed broadband but NPPF,
paragraph 118 requires planning policies to support the expansion of electronic communications
networks, including next generation mobile technology (such as 5G) and full fibre broadband
connections. Policies should set out how high-quality digital infrastructure, providing access to
services from a range of providers, is expected to be delivered and upgraded over time; and
should prioritise full fibre connections to existing and new developments.
In January 2023, amendments were published to the Building Act requiring that new homes are
installed with the fastest broadband connections (gigabit) available within a cost cap. Even where
a gigabit-capable connection is not possible within this cost cap, the new homes will be futureproofed with physical infrastructure to support gigabit-capable connections when they become
available. This is also important given the increase in home working following the pandemic.
The EDG contains supplementary planning guidance for Planning for 5G and can be viewed here
and Planning Guidance for digital connectivity focused on fixed line broadband connections. ECC
has published its Digital Strategy for Essex (2022) which seeks to further expand digital
infrastructure and technologies.
ECC recommend an additional criterion to read:
Proposals for new developments or expansion of existing properties should be capable of
receiving gigabit speed and reliable mobile and broadband connectivity. Proposals will be
supported where the appropriate cabling and ducting is provided to the premises and linked to
infrastructure networks, enabling the fastest available connections. Where connectivity is not
currently available suitable ducting that can accept superfast broadband, fixed line gigabitcable broadband and/or 5G connectivity should be provided to the public highway or other
suitable location.
Non-Policy Action D: Maintaining Local Infrastructure Services
ECC recommend Non-Policy Action D is reviewed as it appears to refer to local infrastructure as
well as more nationally significant infrastructure, namely the Norwich to Tilbury NSIP project, as
outlined in paragraph 7.6.
ECC recommend that Action D only refers to local infrastructure that may arise from any new
development in the Plan area. For the purposes of this Action the widest reasonable definition of
infrastructure and infrastructure providers could be applied and set out in the supporting text.
The term infrastructure can include any structure, building, system facility and/or provision
required by an area for its social and/or economic function and/or wellbeing including (but not
exclusively): footways, cycleways, bridleways and highways; public transport; drainage, SuDs
and flood protection; waste recycling facilities; education and childcare; healthcare; sports,
leisure and recreation facilities; community and social facilities; cultural facilities, including
public art; emergency services; green infrastructure; open space; affordable housing; live/work
units and lifetime homes; broadband; and facilities for specific sections of the community such
as youth or the elderly.
4
In addition, ECC seek reference is made to the ECC Developers' Guide for Infrastructure
Contributions, which outlines the scope and range of infrastructure towards which ECC may seek
contributions from developers and landowners in order to make development acceptable in
planning terms.
5
Great Tey Design Guidelines and Codes (March 2022)
3.3 General principles and guidelines
ECC recommend design principle 2 should also refer to the `setting’ of heritage assets consistent
with NPPF, paragraph 201.
3.4 General design guidelines and codes
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
Code 2 Development affecting listed and unlisted heritage assets
With regards Design guideline 2, ECC recommend reference should also be made to the `setting’
of heritage assets consistent with NPPF, paragraph 201.
New development proposals should not be visually intrusive or block key views to and from
heritage assets and their setting, as shown in F.2. T
Code.3 Set in rural landscape/ development edges
With regards Design guideline 2, ECC supports new development conserving existing native trees
along lanes but consideration needs to be given to any impact on highway safety and visibility
splays. Detailed guidance is provided in the EDG - Highways Technical Manual - planting in sight
splays..
With regards Design guideline 7, ECC supports the principle of green corridors providing
additional pedestrian and cycle links. Please see comments to Code 8 with regards establishing
multifunctional greenways and their design requirements, namely to be consistent with Cycling
infrastructure design (LTN 1/20).
Code.4 Patterns of growth within the rural landscape
With regards Design guideline 2, ECC recommend reference is made to the need for new
development to also consider the `setting’ of heritage assets consistent with NPPF, paragraph
201.
New development in close proximity to designated and non-designated heritage assets and
their setting must propose green screenings to mitigate any unpleasant visual impact, while
also preserving key views;
With regards Design guideline 7, ECC recommends reference is also made to the need to
maintain safety along any lane for all users (pedestrians, cyclists, horseriders and vehicles). ECC
also recommend `increase’ is replaced by `impact’.
Any proposal that would adversely affect the physical appearance of a rural lane, or give rise
to an unacceptable impact increase on in the amount of traffic, noise, safety or disturbance
arising from traffic must be avoided.
6
With regards Design guideline 8, ECC recommends reference is made to the multifunctional
green network strategy.
`… is encouraged to form part of the multifunctional green network strategy (no.4); and
With regards Design guideline 9, ECC recommend any signage is located so that it does not
impact upon visibility of the highway network and should be consulted as the highway authority.
All requests for signs need to comply with Traffic Signs Regulations and General Directions 2016
and other ECC policies. Any scheme investigation will also consider street clutter, available
highway land and relationship to any utility equipment. Usually the appropriate signs are identified
when a development is agreed and the impact of traffic on the wider network is assessed. Local
signage may also be progressed through the Colchester Local Highways Panel.
Code 7 Accessible and attractive footpath network/ access to the countryside
ECC recommend the correct terminology is consistently used with regards the terms ‘footpaths’
and ‘footways’ throughout the document. For example, pavements beside public roads are not
public footpaths and are better referenced as footways. Public footpaths are shown on definitive
maps recording Public Rights of Way where anyone has the legal right to use on foot.
ECC recommend the title is amended to refer to `footway and footpath’ network.
ECC suggest the following clarifications on this matter:
• Design guideline 1 – amend `footpaths’ to `footways’ as these relate to more urban streets
than Public Rights of Way (PRoW)
• Design guideline 2 - reference to `multifunctional’ should be included to read:
Where possible, new proposed footpaths should link up green spaces and woodlands to
create a network of multifunctional green walking routes and promote biodiversity. For
example, the Strategic Wildlife Corridors, as shown in F.44, could include footpath
connections and other green links that could connect new development and form part of
an a multifunctional integrated green infrastructure network;
• Design guideline 4 – reference should be made to new signposts being located so that it
does not impact upon visibility of the highway network and any proposals should be
considered by the highway authority. Please refer to comments regarding Code 4,
Guideline 7.
• Design guideline 5 – amend to `footpath’ to ‘footway’’
Code 8 Prioritise walking and cycling
ECC suggest the following clarifications on this matter:
• Paragraph 1 – refer to `There is an extensive network of footways and footpaths public
footpaths and rights of way in the parish.’
• Design guideline 2 – amend `favour’ to `prioritise’ to be consistent with the Code 8 title,
Design guideline 4 and the new Highway Code. The latter states that drivers must be
aware that pedestrians, cyclists, horse riders, carriage drivers and motorcyclists, as the
most vulnerable road users, should take priority over cars.
• Design guideline 2,3 and 4 – replace `footpath’ with `footway’.
Code 9 People-friendly streets and green links
ECC welcomes the requirement for new footpaths/footways to link up with green and blue
infrastructure to create a network of green walking routes and promote biodiversity. ECC
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recommend reference is made to establishing `multifunctional greenways’ to promote sustainable
and active travel movements and contribute to health and wellbeing.
ECC welcomes the aim to prioritise walking and cycling to help get people healthier and to gain
access with nature. ECC support the principle of establishing multifunctional greenways to
promote sustainable and active travel movements and contribute to health and wellbeing. Any
design of new routes will be required to be consistent with Cycling infrastructure design (LTN
1/20) and to be coherent (allow people to reach day to day destinations easily); direct, safe,
comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
Any pedestrian and cycle links being bordered with rich vegetation and trees should require
consultation with the highway authority given the potential danger to pedestrians and cyclists of
overhanging hedges as well as any impact on highway safety and visibility splays. Detailed
guidance is provided in the EDG - Highways Technical Manual - planting in sight splays. ECC
seeks to be consulted upon any relevant tree planting in proximity to the highway, walking and
cycling routes where the future height, breadth and root growth may impact upon user safety.
ECC recommend design guideline 1 is amended requiring street design being required to have
regard to the standards set out in the EDG - Highways Technical Manual. The prioritisation of
vulnerable users is also consistent with the Highway Code (see response to Code 8)
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
With regards Design guideline 2, ECC recommend reference to`streets should not be built to
maximise vehicle speed or capacity’ should be deleted and replaced with reference to the EDG
Highways Technical Manual - Street Type Table (A to H) in terms of the type of street and
recommended speed limit.
Within the development boundaries, streets should be constructed consistent with their street
type and speed limit, having regard to the EDG Highways Technical Manual - Street Type
Table (A to H) in not be built to maximise vehicle speed or capacity. A range of traffic calming
measures could be introduced by design
With regards Design guideline 4 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
With regards Design guideline 5 – ECC considers reference is made to multifunctional green
infrastructure, as they promote sustainable and active travel movements, contribute to health and
wellbeing, and can be incorporated within sustainable drainage measures (consistent with Code
12, Design principle 2).
Streets must respect the existing vegetation, while also incorporating new opportunities for
landscaping, multifunctional green infrastructure, which may incorporate and sustainable
drainage measures; and
With regards Design guideline 6 – ECC recommend the access street dimensions (page 35);
residential street key dimensions (page 37)and edge lanes key dimension (page 39) should be
reviewed against the EDG Highways Technical Manual - Street Type Table (A to H) for
consistency.
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Reference should be made to the provision of bus stops, where appropriate, which must provide
seating and shelter, raised kerb, ancillary infrastructure, real time information (where appropriate)
and be designed in keeping with the character of the local area. Further guidance is provided in
the EDG and can be found here.
Code 10 Parking and servicing
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They have
been subject to two consultations with LPAs and developers. The standards are being revised to
reflect changes in the new Use Class Orders and national planning policy. Different standards
are required in different areas based on levels of accessibility, namely town centres (highly
accessible); rural (poorly accessible); and other areas (moderately accessible). Details also cover
electric vehicle charging requirements for both residential and non-residential uses. More detailed
design guidance is also provided for both residential and commercial cycle parking taking account
of LTN 1/20 guidance.
With regards Design guideline 1 – please see comments to Code 15 Trees.
With regards Design guideline 4, ECC welcome the reference to the need to be able to charge
electric vehicles. Please se comments under Code.30 Electric vehicle charging points.
Code 11 Cycle parking
ECC recommend reference is made to new development being required to “have regard to the
vehicle parking standards set out in the Essex Parking Standards – Design and Good Practice
(2009) when determining planning applications”. These parking standards are currently being
reviewed by the Essex Planning Officers’ Association (EPOA) and can be viewed here. More
detailed design guidance is also provided for both residential and commercial cycle parking taking
account of LTN 1/20 guidance.
With regards Design guideline 3 – Houses without garages, the emerging parking standards state
that any external access to a location where bicycles can be stored should enable cycles not to
be wheeled through the house, preferably within the property boundary, as opposed to shared
facilities. The bike storage should be covered, secure and large enough to house the number of
bikes/spaces required in line with the standards for that type of use. The emerging standards
require a door width of at least 1.0m should be provided upon access to storage facilities when
provided within the footprint of the dwelling or as a freestanding shed. In flatted developments the
cycle store should be incorporated within the building but accessed directly from the outside with
a minimum recommended door width of 1.2m.
ECC recommend the following amendment and to Figure 33.
When provided within the footprint of the dwelling or as a free standing shed, cycle parking
should be accessed by means of a door at least 1.0m 900mm and the structure should be at
least 2m deep; and
With regards Design guideline 1 – Houses with garages – reference is made to minimum garage
size being 7m x 3m to allow space for cycle storage. This is consistent with the emerging parking
standards dimensions, which includes space for storage and cycle parking.
Code 12 Create a green network
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ECC seek clarification as to whether this section will be reviewed to take account of the published
National Green Infrastructure Framework (2023) and the Essex Green Infrastructure Strategy
(2020) and the Essex Green Infrastructure Standards (June 2022).
ECC support the principle of establishing multifunctional greenways to promote sustainable and
active travel movements, contribute to health and wellbeing and increase opportunities for access
to nature. Any design of new routes will be required to be consistent with Cycling infrastructure
design (LTN 1/20) and to be coherent (allow people to reach day to day destinations easily);
direct, safe, comfortable and attractive, as referenced in paragraph 1.5.2 of the guidance.
The title should be amended to refer to `multifunctional green network’ with similar references in:
• Paragraph 1 - ` A well connected multifunctional green network..’
• Design guideline 1 – ‘Multifunctional gGreen networks should…’
• Design guideline 2 - ‘…design of the multifunctional green network…’
• Design guideline 4 – ‘…when designing for a multifunctional green network…’
• Design guideline 5 - `Multifunctional gGreen networks could contain..’
Code 13 Biodiversity
Through ensuring BNG delivers not only benefits for biodiversity, but more widely through the
multifunctionality of GI, BNG can deliver socioeconomic benefits simultaneously. ECC
recommend reference is made to securing net gain in biodiversity rather than simply biodiversity.
In particular, as of 12th February 2024 all major planning applications have a mandatory
requirement to deliver a minimum of 10% BNG consistent with the Environment Act 2021. The
requirement relates to small sites from 2 April 2024.
ECC recommend Design guideline 3 is strengthened to read:
New development proposals should create aim for the creation of new habitats and wildlife
corridors, e.g. by aligning back and front gardens or installing bird boxes or bricks in walls;
Code 14 Water management
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly with regards greenfield and brownfield run off rates, climate change
allowances, water quality, rainwater reuse/harvesting, green spaces and biodiversity.
ECC recommend reference is made to arrangements for SuDS maintenance and their adoption.
It is the LLFA’s preference that the drainage network and its accompanying SuDS features are
adopted by a public body where possible to ensure lifelong maintenance, and any public body
should be engaged early in the design process.
Code 15 Trees
With regards Design guideline 7 - any tree planting within new development will be required to
contribute a commuted sum for maintenance issues associated with street tree planting.
Interested parties should work with highways officers to ensure that the right trees are planted in
the right places, and solutions are found that are compatible with highways standards and the
needs of different users consistent with NPPF, paragraph 136. Reference should be made to the
EDG: Highways Technical Manual - Planting in sight splays.
Code.17 Development layout
With regards Design guideline 3 – ECC considers it is unclear why priority is given to multiple
choices of routes to be made on foot only. The new Highway Code states that pedestrians,
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cyclists, horse riders, carriage drivers and motorcyclists, as the most vulnerable road users,
should take priority over cars. As a minimum reference should be made to pedestrians and
cyclists as these are the more popular modes within new developments.
Code.20 Housing mix
With regards Design guideline 1, ECC recommend reference could be amended to be consistent
with NPPF, paragraph 70b in relation to LPAs being required to promote the development of a
good mix of sites including small sites to come forward for community-led development for
housing and self-build and custom-build housing;
New development should proposed a mix of housing to include a range of house types and
sizes, both developer and community-led development for housing and self-build and custombuild self built, to allow for a variety of options and bring balance to the population profile; and
Code.22 Legibility and wayfinding
ECC welcomes reference in Design guidelines 5 and 6 to providing signage for existing and newly
proposed footpaths and cycle lanes. However, ECC recommend any signage is located so that it
does not impact upon visibility of the highway network and should be consulted as the highway
authority. Local signage may also be progressed through the Colchester Local Highways Panel.
Code.23 Boundary lines, boundary treatments and corner treatment
With regards Design guideline 8, ECC recommend reference to streets being designed to slow
traffic is deleted as this depends on the type of street. The EDG Highways Technical Manual -
Street Type Table (A to H) sets out requirements for different types of street including their
recommended speed limit.
ECC recommend this guideline is amended to be consistent with the necessary change to Code
9, Design guideline 1 to read:
Streets must have regard to meet the technical highways standards set out in the Essex Design
Guide requirements, as well as being considered a ‘place’ to be used by all. It is essential that
the design of new development includes streets and junctions that incorporate the needs of
pedestrians, cyclists, and if applicable, public transport users;
Code.25 Hard landscaping, materials and street furniture
With regards Design guideline 3 – please refer to response to Code 15 Trees.
Code 26 Minimising energy use
With regards Design guidelines 8 and 9, ECC recommend reference should be made to new
development being required to have regard to the EDG - Climate Change guidance. This provides
guidance on how to design developments (of all scales and types) to meet the net zero carbon
and energy standards, mitigate potential overheating risk and to address other inter-related
sustainability issues. The aim is to ensure new development mitigates, adapts and is resilient to
a changing climate.
ECC, through the Essex Climate and Planning Unit (CaPU). has recently published a number of
policy and evidence base documents to support emerging Local Plans and the determination of
planning applications to move towards net zero development, which can be viewed here.
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A recommended `Planning Policy Position for Net Zero Carbon Development Homes and
Buildings in Greater Essex’ has been prepared in collaboration with Essex LPAs, and can be
downloaded here. The position document sets out the recommended planning policy for Local
Planning Authorities in Greater Essex to embed in their Local Plans (and other associated
planning documents) to ensure that all new homes and buildings achieve a consistent, clearly
defined, net zero carbon (in operation) standard that aligns with local and national climate targets
and delivers high quality, healthy, energy efficient, climate resilient homes and buildings. The
position document includes a ‘place holder policy’ for tackling embodied carbon emissions from
new build development which is an interim measure to be used in local plan consultations,
pending the outputs of the Embodied Carbon Study for Essex. The Embodied Carbon Study for
Essex is due to report in April 2024.
It is expected that this Policy will be incorporated into the Colchester Local Plan Review and other
Essex LPAs following scrutiny at examination in due course. This will then be able to provide the
necessary strategic policy for the plan area on this matter.
Code.28 Minimising construction waste
ECC support reference in paragraph 2 regarding developers being required to prepare a Site
Waste Management Plans. This is consistent with Mineral Local Plan Policy 4 - Reducing the use
of Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.29 Recycling materials and buildings
ECC support this code as it is consistent with Mineral Local Plan Policy 4 - Reducing the use of
Mineral Resources and promoting Sustainable Construction. The applicant is required to
demonstrate compliance with the notion of sustainable development, circular economy principles
and the application of procurement policies promoting sustainable design and construction in
proposed development. ECC, as Minerals and Waste Planning Authority, can advise on the
requirements.
Code.30 Electric vehicle charging points
ECC has prepared an Electric Vehicle Charge Point Strategy to deliver `the Right Charger in the
Right Place’ so that by 2030, residents, businesses and visitors in Essex, where car travel is
necessary, will be able to use electric vehicles and be assured there is an accessible, reliable,
easy-to-use, safe and fairly priced charging network. The Strategy will be refreshed by 2025
(Phase 2 Strategy) to look at longer-term private car use and EV uptake. It will explore the supply
of renewable energy to EV charge points and how the conversion of public transport, taxis and
freight vehicles to cleaner fuels can be achieved. Separate strategies will be developed to provide
for alternative clean and zero emission fuels, such as hydrogen.
The Essex Parking Standards – Design and Good Practice (2009) are currently being reviewed
by the Essex Planning Officers’ Association (EPOA) and can be viewed here. They include details
covering electric vehicle charging requirements and standards for both residential and nonresidential uses, including on and off-street locations.
Once these standards have been approved it is expected that they will be a material consideration
to which new development will need to have regard to at an early stage of the design process.
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With regards Off-street car parking, ECC supports the provision of mounted charging points being
integrated into the design of new developments regarding homes. Reference could also be made
to the following requirements for commercial developments.
Commercial developments must provide suitable charging systems for a proportion of the total
number of parking spaces to be provided. Ducting and infrastructure should be in place to
install additional EVCPs when future demand dictates.
Code.31 Storage and slow release
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 and that the Design principles are consistent with the ECC
SuDS Guide, particularly the section regarding rainwater re-use, which can be viewed here.
The LLFA expects the management of surface water to follow the drainage hierarchy. With
concern over climate change and increasing risk of water scarcity, re-use of rainwater wherever
possible should be utilised. Therefore, in accordance with the drainage hierarchy contained in
Approved Document H of the Building Regulations, Planning Practice Guidance and the need to
mitigate against water scarcity, all surface water run off must aim to be discharged as high up the
following hierarchy as possible:
▪ Rainwater re-use (rainwater harvesting/greywater recycling)
▪ An adequate soakaway or other infiltration system
▪ Hybrid solution of infiltration and discharging to a surface water body
▪ To a surface water body (e.g. an ordinary watercourse)
▪ To a surface water sewer, highway drain, or other drainage system
▪ To a combined sewer
Code.32 Permeable paving
As Lead Local Flood Authority, ECC recommend reference is made to the Sustainable Drainage
Systems Design Guide for Essex 2020 with regards the necessary regulations, standards, and
guidelines relevant to permeable paving and sustainable drainage, and which can be viewed
here.
As the LLFA, for outline applications, preliminary ground investigations, or a desk top study
highlighting the potential capacity for infiltration should be provided. For full applications or where
necessary for discharge of conditions applications, full detailed infiltration testing needs to be
provided in line with BRE365 and the infiltration testing methods found in chapter 25.3 of the
CIRIA SuDS Manual C753. This should include the locations and results. The lowest found rate
should be used as a conservative approach.
4. Delivery
ECC recommend reference should be made to new development being required to also have
regard to the Essex Design Guide (EDG) as well as this guide, as recommended in the response
to Policy GTTEY1: Design. The EDG contains a much wider scope, including a Highways
Technical Manual; Sustainable Drainage Systems Design Guide for Essex of which ECC is the
statutory and/or Lead Authority; and newer sections regarding Garden Communities; Ageing
Populations; and Health and Wellbeing. More recent additions include Planning for 5G and Solar
Farm Guiding Principles.
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Many references have been made to the EDG in the responses to individual Codes and their
Design guidelines.