Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

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

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

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

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

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

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

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

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

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

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

SEE ATTACHMENT

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

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

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

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

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

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

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

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

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

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