Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

We welcome the opportunity to comment on the Preferred Options version of the emerging
Colchester Local Plan. As a medium‑sized, locally based housebuilder with a long track record
of delivering high‑quality homes across the borough, we strongly support the Council’s
ambition to meet local housing needs, strengthen communities, and ensure that growth is
delivered in a sustainable and coordinated manner.
However, we have significant concerns that several of the key development sites identified in
the Preferred Options document remain effectively undevelopable due to unresolved constraints
relating to wastewater treatment capacity - particularly at the Langham and West Bergholt
Water Recycling Centres (WRCs). Unless these constraints are addressed early and decisively,
the Local Plan risks allocating land that cannot be delivered within the plan period,
undermining both housing supply and the credibility of the spatial strategy.
In addition, we believe the Plan should go further in recognising the challenges faced by
medium‑sized builders, particularly in relation to regulatory burden, development viability, and
the cumulative impact of policy requirements. Without a more proportionate and enabling
approach, the Plan risks reducing the diversity of the local housebuilding sector and slowing
the rate of delivery.
Wastewater Treatment Capacity as a Binding Constraint on Housing Delivery
a) Current capacity limitations at Langham and West Bergholt WRCs
The Preferred Options document acknowledges that wastewater treatment capacity is a critical
infrastructure dependency for several proposed allocations. However, the scale and immediacy
of the issue is understated. Both Langham WRC and West Bergholt WRC are currently
operating at or near their permitted capacity. We understand from engagement with Anglian
Water that:
Tel: 01206 392613
e: info@rosebuilders.co.uk
w: www.rosebuilders.co.uk
Our Ref: WV/COL01
12 January 2026
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
- No additional headroom exists to accommodate the scale of growth proposed in the Local
Plan, particularly in the northern and western parts of the borough.
- Upgrades to both WRCs will require multi‑year investment programmes, including design,
consenting, and construction phases.
- Delivery of upgrades is not currently aligned with the Local Plan trajectory, meaning that
several allocations cannot realistically come forward until the latter part of the plan period
if at all.
These constraints are not theoretical. They represent a hard environmental and regulatory limit
on development. Without confirmed investment, timing, and funding mechanisms for WRC
upgrades, the affected sites cannot be considered “deliverable” or even “developable” under the
NPPF definitions.
b) Impact on key allocations
A number of strategic and medium‑sized sites in the Preferred Options document fall within the
catchments of Langham and West Bergholt WRCs. These include sites that the Council is
relying on to deliver early‑to‑mid‑plan‑period housing numbers. If wastewater capacity is not
resolved, the following risks arise:
- Housing delivery will be delayed, potentially by several years.
- The five‑year housing land supply will be undermined, exposing the Council to speculative
development.
- The spatial strategy will become unbalanced, with growth pushed toward areas with fewer
constraints but potentially less alignment with sustainable development principles.
- Developers will face prolonged uncertainty, making it difficult to commit to land
acquisition, design work, and investment.
We strongly recommend that the Local Plan includes a clear, costed, and time‑bound
infrastructure delivery plan for wastewater upgrades, prepared in partnership with Anglian
Water. Without this, the allocations dependent on Langham and West Bergholt WRCs should
not be relied upon for early delivery.
c) Need for a coordinated, proactive approach
To avoid a situation where wastewater constraints stall the entire housing programme, the
Council should:
- Work with Anglian Water to secure early funding commitments for WRC upgrades.
- Explore phased or modular upgrade options that could unlock partial capacity sooner.
- Ensure that the Infrastructure Delivery Plan is aligned with the housing trajectory, not
treated as an afterthought.
A Local Plan that allocates undeliverable sites risks failing the tests of soundness. Addressing
wastewater capacity is therefore essential to ensuring the Plan is effective and justified.
Supporting Medium‑Sized Builders Through Proportionate Regulation
a) The importance of medium‑sized developers
Medium‑sized builders play a vital role in Colchester’s housing market. We:
- Deliver small‑to‑medium sites that larger developers often overlook.
- Build at a faster rate once on site.
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
- Provide design diversity and local character.
- Support local employment and supply chains.
However, the cumulative regulatory burden - particularly around nutrient neutrality,
biodiversity net gain, design codes, and technical standards - has disproportionately affected
medium‑sized firms. Unlike national volume housebuilders, we do not have large compliance
teams or the ability to absorb prolonged delays.
b) The need for a proportionate policy approach
We urge the Council to adopt a more flexible and enabling approach in the Local Plan,
including:
- Clear, streamlined requirements for smaller and medium‑sized sites.
- Avoiding unnecessary duplication between local policies and national standards.
- Ensuring that policy requirements are viability‑tested, particularly where multiple
obligations apply simultaneously.
- Providing template guidance and standardised methodologies to reduce the cost and
complexity of compliance.
A Local Plan that is overly prescriptive risks excluding medium‑sized builders from the market,
reducing competition and slowing delivery.
Viability and Deliverability
a) Cumulative policy burden
The Preferred Options document includes a wide range of policy requirements relating to:
- Affordable housing
- Biodiversity net gain
- Sustainable construction
- Design quality
- Open space
- Infrastructure contributions
Individually, these policies may be justified. Collectively, they risk rendering many sites
unviable - particularly in areas where land values are modest or where significant abnormal
costs (such as wastewater upgrades) already exist.
b) Ensuring realistic viability assumptions
We recommend that the Council:
- Undertakes robust, site‑specific viability testing, rather than relying on generic
assumptions.
- Recognises the cost implications of wastewater constraints, including potential developer
contributions.
- Avoids setting policy requirements at the upper limit of viability, leaving no flexibility for
unforeseen costs.
- Allows for phased or reduced obligations on medium‑sized sites where justified.
A plan that is not viable is not deliverable. Ensuring realistic viability assumptions is essential
to maintaining a steady supply of new homes.
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
Conclusions and Recommendations
To ensure that the Local Plan is sound, deliverable, and capable of meeting Colchester’s
housing needs, we recommend that the Council:
1. Address wastewater treatment capacity as a priority, with clear commitments and
timelines for upgrades at Langham and West Bergholt WRCs.
2. Avoid relying on constrained sites for early delivery unless wastewater solutions are
secured.
3. Adopt a proportionate regulatory approach that supports medium‑sized builders and
recognises their contribution to local housing delivery.
4. Ensure that policy requirements are viability‑tested, realistic, and flexible enough to
accommodate site‑specific circumstances.
5. Strengthen the Infrastructure Delivery Plan to align infrastructure investment with the
housing trajectory.
We remain committed to working collaboratively with the Council to deliver high‑quality
homes across the borough. With the right infrastructure and a supportive policy environment,
medium‑sized local developers can play a central role in achieving the ambitions of the new
Local Plan.

We welcome the opportunity to comment on the Preferred Options version of the emerging
Colchester Local Plan. As a medium‑sized, locally based housebuilder with a long track record
of delivering high‑quality homes across the borough, we strongly support the Council’s
ambition to meet local housing needs, strengthen communities, and ensure that growth is
delivered in a sustainable and coordinated manner.
However, we have significant concerns that several of the key development sites identified in
the Preferred Options document remain effectively undevelopable due to unresolved constraints
relating to wastewater treatment capacity - particularly at the Langham and West Bergholt
Water Recycling Centres (WRCs). Unless these constraints are addressed early and decisively,
the Local Plan risks allocating land that cannot be delivered within the plan period,
undermining both housing supply and the credibility of the spatial strategy.
In addition, we believe the Plan should go further in recognising the challenges faced by
medium‑sized builders, particularly in relation to regulatory burden, development viability, and
the cumulative impact of policy requirements. Without a more proportionate and enabling
approach, the Plan risks reducing the diversity of the local housebuilding sector and slowing
the rate of delivery.
Wastewater Treatment Capacity as a Binding Constraint on Housing Delivery
a) Current capacity limitations at Langham and West Bergholt WRCs
The Preferred Options document acknowledges that wastewater treatment capacity is a critical
infrastructure dependency for several proposed allocations. However, the scale and immediacy
of the issue is understated. Both Langham WRC and West Bergholt WRC are currently
operating at or near their permitted capacity. We understand from engagement with Anglian
Water that:
Tel: 01206 392613
e: info@rosebuilders.co.uk
w: www.rosebuilders.co.uk
Our Ref: WV/COL01
12 January 2026
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
- No additional headroom exists to accommodate the scale of growth proposed in the Local
Plan, particularly in the northern and western parts of the borough.
- Upgrades to both WRCs will require multi‑year investment programmes, including design,
consenting, and construction phases.
- Delivery of upgrades is not currently aligned with the Local Plan trajectory, meaning that
several allocations cannot realistically come forward until the latter part of the plan period
if at all.
These constraints are not theoretical. They represent a hard environmental and regulatory limit
on development. Without confirmed investment, timing, and funding mechanisms for WRC
upgrades, the affected sites cannot be considered “deliverable” or even “developable” under the
NPPF definitions.
b) Impact on key allocations
A number of strategic and medium‑sized sites in the Preferred Options document fall within the
catchments of Langham and West Bergholt WRCs. These include sites that the Council is
relying on to deliver early‑to‑mid‑plan‑period housing numbers. If wastewater capacity is not
resolved, the following risks arise:
- Housing delivery will be delayed, potentially by several years.
- The five‑year housing land supply will be undermined, exposing the Council to speculative
development.
- The spatial strategy will become unbalanced, with growth pushed toward areas with fewer
constraints but potentially less alignment with sustainable development principles.
- Developers will face prolonged uncertainty, making it difficult to commit to land
acquisition, design work, and investment.
We strongly recommend that the Local Plan includes a clear, costed, and time‑bound
infrastructure delivery plan for wastewater upgrades, prepared in partnership with Anglian
Water. Without this, the allocations dependent on Langham and West Bergholt WRCs should
not be relied upon for early delivery.
c) Need for a coordinated, proactive approach
To avoid a situation where wastewater constraints stall the entire housing programme, the
Council should:
- Work with Anglian Water to secure early funding commitments for WRC upgrades.
- Explore phased or modular upgrade options that could unlock partial capacity sooner.
- Ensure that the Infrastructure Delivery Plan is aligned with the housing trajectory, not
treated as an afterthought.
A Local Plan that allocates undeliverable sites risks failing the tests of soundness. Addressing
wastewater capacity is therefore essential to ensuring the Plan is effective and justified.
Supporting Medium‑Sized Builders Through Proportionate Regulation
a) The importance of medium‑sized developers
Medium‑sized builders play a vital role in Colchester’s housing market. We:
- Deliver small‑to‑medium sites that larger developers often overlook.
- Build at a faster rate once on site.
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
- Provide design diversity and local character.
- Support local employment and supply chains.
However, the cumulative regulatory burden - particularly around nutrient neutrality,
biodiversity net gain, design codes, and technical standards - has disproportionately affected
medium‑sized firms. Unlike national volume housebuilders, we do not have large compliance
teams or the ability to absorb prolonged delays.
b) The need for a proportionate policy approach
We urge the Council to adopt a more flexible and enabling approach in the Local Plan,
including:
- Clear, streamlined requirements for smaller and medium‑sized sites.
- Avoiding unnecessary duplication between local policies and national standards.
- Ensuring that policy requirements are viability‑tested, particularly where multiple
obligations apply simultaneously.
- Providing template guidance and standardised methodologies to reduce the cost and
complexity of compliance.
A Local Plan that is overly prescriptive risks excluding medium‑sized builders from the market,
reducing competition and slowing delivery.
Viability and Deliverability
a) Cumulative policy burden
The Preferred Options document includes a wide range of policy requirements relating to:
- Affordable housing
- Biodiversity net gain
- Sustainable construction
- Design quality
- Open space
- Infrastructure contributions
Individually, these policies may be justified. Collectively, they risk rendering many sites
unviable - particularly in areas where land values are modest or where significant abnormal
costs (such as wastewater upgrades) already exist.
b) Ensuring realistic viability assumptions
We recommend that the Council:
- Undertakes robust, site‑specific viability testing, rather than relying on generic
assumptions.
- Recognises the cost implications of wastewater constraints, including potential developer
contributions.
- Avoids setting policy requirements at the upper limit of viability, leaving no flexibility for
unforeseen costs.
- Allows for phased or reduced obligations on medium‑sized sites where justified.
A plan that is not viable is not deliverable. Ensuring realistic viability assumptions is essential
to maintaining a steady supply of new homes.
ROSE
ROSE BUILDERS LIMITED
Directors: S W J Rose BSc FCIOB – A L Auger – A M Bowles BSc FCA – S D Brown BSc MCIOB – C M Wright – T W Rose MEng
Registered in England No. 03106982 VAT Reg No. 123 3893 19
Conclusions and Recommendations
To ensure that the Local Plan is sound, deliverable, and capable of meeting Colchester’s
housing needs, we recommend that the Council:
1. Address wastewater treatment capacity as a priority, with clear commitments and
timelines for upgrades at Langham and West Bergholt WRCs.
2. Avoid relying on constrained sites for early delivery unless wastewater solutions are
secured.
3. Adopt a proportionate regulatory approach that supports medium‑sized builders and
recognises their contribution to local housing delivery.
4. Ensure that policy requirements are viability‑tested, realistic, and flexible enough to
accommodate site‑specific circumstances.
5. Strengthen the Infrastructure Delivery Plan to align infrastructure investment with the
housing trajectory.
We remain committed to working collaboratively with the Council to deliver high‑quality
homes across the borough. With the right infrastructure and a supportive policy environment,
medium‑sized local developers can play a central role in achieving the ambitions of the new
Local Plan.