Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

We support the overall direction of Policy EN6, and particularly the requirement for Heritage Impact Assessments for proposals related to or impacting on the setting of heritage assets. However, we recommend that the Council review the first paragraph, which addresses substantial harm to or total loss of significance of designated and non-designated heritage assets, to ensure consistency with the National Planning Policy Framework (NPPF).

Distinction between designated and non-designated heritage assets
It is particularly important that the policy distinguishes clearly between the tests of harm applicable to designated and non-designated heritage assets. Paragraph 214 of the NPPF sets out a high bar for substantial harm or total loss of designated heritage assets, requiring clear and convincing justification and demonstration of substantial public benefits. In contrast, paragraph 216 requires a balanced judgement for non-designated heritage assets, having regard to the scale of harm and the asset’s significance. These distinct approaches should be reflected accurately in the policy wording to avoid conflation.

We welcome and support Policy EN7.

Like many potential allocations in Colchester, site PP1 lies within the setting of several designated heritage assets and therefore has the potential to affect their significance. We welcome the Council’s Heritage Impact Assessment (HIA) Sift (January 2025), prepared by Place Services, which correctly identifies these sensitivities. The heritage assets include two Conservation Areas, six Grade II listed buildings, and, most notably, the St Botolph's Augustinian Priory Scheduled Monument (LEN 1013764), which the site adjoins. We also welcome the specific reference to these at criterion ‘e’.
Initial assessment

Effects uncertain. Given the sensitivity of this site, we agree that a full Heritage Impact Assessment will be necessary to inform the next draft of the Local Plan. This will help determine whether the site is suitable from a historic environment perspective and to identity any mitigation measures or opportunities for enhancement. We understand from the Council (December 2025) that detailed HIAs for sites requiring a Proforma or full assessment have been considered within a Stage 2 report, which is expected to be published in January 2026. We look forward to reviewing this and providing further comments as necessary in due course.

Like many potential allocations in Colchester, site PP1 lies within the setting of several designated heritage assets and therefore has the potential to affect their significance. We welcome the Council’s Heritage Impact Assessment (HIA) Sift (January 2025), prepared by Place Services, which correctly identifies these sensitivities. The heritage assets include two Conservation Areas, six Grade II listed buildings, and, most notably, the St Botolph's Augustinian Priory Scheduled Monument (LEN 1013764), which the site adjoins. We also welcome the specific reference to these at criterion ‘e’.

Initial assessment

Effects uncertain. Given the sensitivity of this site, we agree that a full Heritage Impact Assessment will be necessary to inform the next draft of the Local Plan. This will help determine whether the site is suitable from a historic environment perspective and to identity any mitigation measures or opportunities for enhancement. We understand from the Council (December 2025) that detailed HIAs for sites requiring a Proforma or full assessment have been considered within a Stage 2 report, which is expected to be published in January 2026. We look forward to reviewing this and providing further comments as necessary in due course.

Site PP2 lies within the setting of several designated heritage assets and therefore has the potential to affect their significance. We welcome the Council’s Heritage Impact Assessment (HIA) Sift (January 2025), prepared by Place Services, which correctly identifies these sensitivities. The assets include the Colchester Area 1 Conservation Area, which partly overlaps the site, numerous listed buildings, and, most notably, the St Botolph's Augustinian Priory Scheduled Monument (LEN 1013764), which directly adjoins the site. We also welcome the specific reference to these at criterion ‘f’.
Initial assessment
Effects uncertain. Given the sensitivity of this site, we agree that a full Heritage Impact Assessment will be necessary to inform the next draft of the Local Plan. This will help determine whether the site is suitable from a historic environment perspective and to identity any mitigation measures or opportunities for enhancement. We understand from the Council (December 2025) that detailed HIAs for sites requiring a Proforma or full assessment have been considered within a Stage 2 report, which is expected to be published in January 2026. We look forward to reviewing this and providing further comments as necessary in due course.

Site PP3 is located within the Colchester Area 1 Conservation Area and surrounded by numerous listed buildings. As before we welcome the Council’s Heritage Impact Assessment (HIA) Sift (January 2025), prepared by Place Services, which correctly identifies these sensitivities.
Given the sensitivity of this site, a full Heritage Impact Assessment will be necessary to inform the next draft of the Local Plan. This will help determine whether the site is suitable from a historic environment perspective and identify any mitigation measures or opportunities for enhancement. However, it is unclear from the information provided whether a new HIA is planned for this site. The Sift report suggests that the Council may rely on a 2021 HIA, but it is not evident whether that earlier assessment has informed the current site boundary or the content of Policy PP3.
Initial assessment
Effects uncertain. A full Heritage Impact Assessment will be necessary to inform the next draft of the Local Plan. If the Council plans to rely on the 2021 HIA, we recommend confirming that it remains relevant and updating it where needed so that it reflects the current site boundary, policy wording, and best practice guidance.
If, once prepared, the evidence shows that harm cannot be adequately mitigated, the site should not be allocated.

Site PP5 is within the wider setting of the Grade II listed Braiswick farmhouse (LEN 1337395).

Initial assessment

While development at this site may be acceptable, we agree that a Heritage Impact Assessment (Proforma) will be necessary to confirm the site’s suitability from a historic environment perspective and to identify any mitigation measures or opportunities for enhancement. The resulting recommendations should then be incorporated into criterion ‘f’.

We have serious concerns regarding this site which adjoins and includes part of the Moat Farm Dyke: a northern extension of Lexden Dyke; part of the Iron Age territorial oppidum and Romano-British town of Camulodunum Scheduled Monument (LEN 1019964) and is potentially within the wider setting of two Grade II listed buildings.
Given this sensitivity, a full Heritage Impact Assessment will be necessary before the next draft of the Plan to determine whether the site is suitable from a historic environment perspective and to identity any mitigation measures or opportunities for enhancement. We understand from the Council (December 2025) that this HIA is expected to be published in January 2026. As previously noted, we have not been able to offer detailed, site-specific comments at this stage due to the high-level nature of the current assessment. However, we will continue to work closely with the Council and provide more detailed advice as further information emerges.

Initial assessment

Effects uncertain. A full Heritage Impact Assessment will be necessary to determine whether the site can be allocated. If this evidence demonstrates that harm cannot be adequately mitigated, the site should be deleted.

The site appears to be within the wider setting of several Grade II listed buildings.

Initial assessment

While development at this site may be acceptable, a Heritage Impact Assessment (Proforma) will be essential to confirm the site’s suitability from a historic environment perspective and to identify appropriate mitigation measures or opportunities for enhancement. The resulting recommendations should then be incorporated into criterion ‘m’.

We have serious concerns regarding the possible allocation of this site, which lies adjacent to the Gosbecks Iron Age and Romano-British Scheduled Monument (LEN 1002180). Given its proximity, there is a strong likelihood of archaeological remains of schedulable quality within the development area, as well as potential impacts arising from development within its setting.
Due to this sensitivity, a full Heritage Impact Assessment, rather than the Proforma HIA recommended by the Sift Report, will be essential before the next draft of the Plan. This assessment should determine whether the site is suitable from a historic environment perspective and identify any mitigation measures or opportunities for enhancement to be incorporated into criterion ‘i’. We will continue to work closely with the Council and provide more detailed advice as further information emerges.

Initial assessment

Effects uncertain. A full Heritage Impact Assessment will be necessary to determine whether the site can be allocated. If this evidence demonstrates that harm cannot be adequately mitigated, PP10 should not be allocated.