Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025
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Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025
Policy ST6: Colchester's Employment Needs
Representation ID: 14073
Received: 14/01/2026
Respondent: Tarmac Ltd
Agent: Aisling O`Kane
Wish to promote land East of Warren Lane.
Support the objective of draft Policy ST6 to provide a range of sites for employment uses. Concerned that requirement of at least 41.7 ha of employment land underestimates actual existing and future demand for floorspace in the area.
expectation is for the Site to be restored following existing extraction activities - excellent opportunity for the currently undesignated central southern portion of the Site to be developed for employment uses. Area comprises limited ecological value due to the activities that have taken place in this location. Not in LWS or open space designations.
We write on behalf of our client, Tarmac Trading Limited ('Tarmac'}, to provide representations to Colchester City Council's ('CCC') Preferred Options Local Plan Regulation 18 Consultation. These representations are made in relation to Land east of Warren Lane, Colchester, CO3 0NN ('the Site'), as shown on the Site Location Plan included within Appendix I.
Supporting Information
In addition to this Letter, the representations are supported by the following:
- Appendix I - Site Location Plan;
- Appendix II - Employment Demand and Need Technical Note, prepared by Marrons;
- Appendix Ill - Transport Appraisal, prepared by Mode Transport Planning.
Introduction
These representations are submitted in relation to the Preferred Options Local Plan Regulation 18 Consultation 2025 to 1) promote the Site for employment uses; and 2) object to the extent of the proposed Strategic Biodiversity Area (Stanway Gravel Pits) that covers the entirety of the Site.
The representations set out details of the Site and surrounding context, the strategic planning context, the reasons why the Site is suitable for employment opportunity and should therefore be allocated for development within the Local Plan and the recent policy and legislative changes that have impacted the principle and quantum of development on the Site.
The representations then investigate the following elements related to the Site and its potential continued employment use: economic benefits, transport and accessibility, ecology, and residential potential.
Tarmac is the UK's leading sustainable building materials and construction solutions business, with over 100,000 acres of land within their control. Tarmac has significant land holdings to the south west of Colchester, including the Site to which these representations relates.
Tarmac is aware of the Call for Sites consultation which was undertaken between 20 October 2023 and 5January 2024. At the time of the consultation, Tarmac was unable to submit a representation for the Site due to uncertainty around the timescales and use of the Site for mineral extraction in the medium to long term. Consequently, the Site has not been assessed within the Strategic Land Availability Assessment ('SLAA') published February 2025.
Subsequently, following the Call for Sites consultation, Tarmac has prepared a clear strategy and timeline for the Site, enabling representations to be made at this stage to promote the Site for employment use to assist with the Local Plan preparation and help CCC set a sound plan and vision for growth. Notably, recent national legislative and policy changes in planning, including the Planning and Infrastructure Act, the adoption of the National Industrial Strategy and the revised consultation National Planning Policy Framework ('NPPF'), further accelerate the need for employment activity and floorspace, and in particular, investment into the industrial and logistics sectors.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
Site and Surrounding Context
The Site is located within the administrative boundary of CCC. The Site is approximately 5km to the south west of Colchester City Centre and circa 150m to the south of the settlement boundary of Colchester. Colchester Railway Station is circa 5.5km to the north east of the Site, with Marks Tey Railway Station Circa 4km to the north west.
The Site is bound by Maldon Road (B1022) to the south, with Colchester Zoo and the 'Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm' scheduled monument beyond. Warren Lane bounds the west of the Site with the Bellhouse Landfill beyond which is also in Tarmac ownership and subject to its own restoration plan. A public bridleway bounds the east of the Site, with the 'Gosbecks Iron Age and Romano-British Site' scheduled monument beyond. To the north there is some mineral extraction land currently being restored and beyond is the Fiveways Fruit Farm which has part detailed, part outline permission (ref. 182220) for 420 homes within the settlement boundary of Colchester.
The Site extends to approximately 94ha and comprises gravel quarry works with associated plant and machinery set amongst lagoons and wooded areas across the Site. The southern boundary of the Site is lined with trees and shrubs. There is one Public Right of Way ('PRoW') through the Site that joins up to Maldon Road to the south of the Site to Warren Lane to the north of the Site.
The Site is ideally located circa 3km from London Road (A12), providing excellent connections to London and Freeport East as well as the wider road network beyond. The Colchester Zoo bus stop is located immediately adjacent to the south of the Site and is served by bus routes onwards to Colchester City Centre and beyond.
The scheduled monuments are not within the Site but do lie within 10m of the boundary to the east and within 10m of part of the boundary to the south. The Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm scheduled monument list entry number is 1490583. The Gosbecks Iron Age and Romano-British site list entry number is 1002180.
There are no listed buildings or conservation areas within the Site. Circa 150m south of the Site is the Grade II* listed Church of All Saints, this is currently set within Colchester Zoo. Circa 220m north east of the Site is the Grade II listed Wiseman's Farmhouse, a private residential property.
There are two areas of Ancient Woodland surrounding the Site; Gol Grove/Hanging Wood west of the Site and Butchers Wood south east of the Site.
Minerals and Waste Position
The Site is currently operated as a mineral extraction and processing facility with ancillary operations. Extraction has largely been completed on the Site with restoration activities progressing. Ongoing processing operations are utilising material being brought in from adjacent areas which will likely be exhausted in the short to medium term (as early as 2030). Recent planning activity (ref. ESS/13/25/COL) has aligned operational planning permissions with this potential end date with restoration (part acid grassland and part woodland) as part of the overall restoration scheme to follow on.
The existing mineral operations are of the utmost importance in providing vital foundation materials to infrastructure and other development projects in the local area, but there is the potential for the site to offer additional development opportunities, either in parallel with ongoing operations, or to follow on from them as they phase out over whatever timescale plays out.
The Site should therefore be considered for an alternative employment use for the medium/long term within the Local Plan.
Essex County Council's ('ECC') Mineral Local Plan ('MLP') was adopted in July 2014. ECC's Minerals and Waste Development Scheme was last updated in November 2019, with the last consultation being the Regulation 18 consultation on the Minerals Local Plan Review in April 2021. Tarmac is promoting an extension extraction site to the MLP to the south west which would continue their operations in the Colchester area and these await further progress on the MLP.
Adopted Local Plan
The adopted Colchester Local Plan up to 2033 is split into two sections, with Section 1 adopted in February 2021 and Section 2 adopted in July 2022.
Within the adopted Local Plan, the northern and western portions of the Site (as outlined in the Site Local Plan) are designated as Public Open Space and there are five Local Wildlife Sites dispersed throughout the Site. There is an area of undesignated land within the central southern portion of the Site.
Emerging Local Plan Preparation
These representations are made to the current Preferred Options Local Plan (Regulation 18) consultation forming part of the preparation of a new Local Plan for Colchester. The Plan will set the strategy for growth in Colchester up to 2041 and once adopted, will replace existing Local Plan Policies. CCC's Local Development Scheme states that submission of the Regulation 19 Plan and Summary of comments will be made in August/ September of 2026.
The Local Plan is supported by an evidence base and supporting documents of which the following are of particular relevance to the Site and its potential for employment use:
Employment Study (February 2025);
Strategic Biodiversity Assessment Uanuary 2025);
Strategic Land Availability Assessment (SLAA): Site Assessments Report Stage 2 (February
2025).
The CCC Preferred Options Local Plan consultation document, and interactive policies map, confirms that, in addition to the existing Open Space and Local Wildlife Site designations, it is proposed to designate the Site as a Local Landscape Character Assessment area and a Strategic Biodiversity Area (Stanway Gravel Pits). An extract of the interactive policy map for the Preferred Options Local Plan is shown in Figure 1.
Figure 1: Interactive Policy Map Extract taken from CCC website (SEE ATTACHMENT)
As set out within the Introduction, these representations seek to promote the Site for employment uses and object to the proposed extent of the Strategic Biodiversity Area (Stanway Gravel Pits) that covers the Site. This is guided by the strategic planning context and the identified need as set out below.
Strategic Planning Context
Planning and Infrastructure Act 2025
The Planning and Infrastructure Bill received Royal Assent on the 18th December 2025. The Act sets rules for infrastructure and planning, introduces a nature restoration levy for developers run by Natural England, updates powers for development corporations and compulsory land purchase, establishes environmental outcomes reports, and covers related matters. The Act is central to the Government's plan to get Britain building again and deliver economic growth. It seeks to speed up and streamline the delivery of new homes and critical infrastructure, supporting the delivery of the Government's Plan for Change milestones of building 1.5 million homes in England and fast tracking 150 planning decisions on major economic infrastructure projects by the end of this Parliament.
The Planning and Infrastructure Act requires the preparation of Spatial Development Strategies ('SDS'). This follows the local government reorganisation driven from the English Devolution White Paper. The vision for Colchester includes three unitary authorities which will form Greater Essex. Greater Essex has already been announced as part of the Devolution Priority Programme and the Government is minded to establish a Mayoral Combined County Authority. CCC will then become part of the North Essex Unitary. The SDS puts a stronger emphasis on delivering housing, employment space and infrastructure at a sub-regional scale. It is, therefore, anticipated that following the adoption of the current draft Local Plan, the next Development Plan for the Site will cover a different spatial areas and be in the form of a Local Plan and a SDS.
We note that housing delivery is directly linked to increased demand for logistics space, with each new home requiring an additional 69 square feet of warehouse space to support its distribution needs (The British Property Federation's What Warehousing Where? Report). Therefore, an additional
25.64 million square feet of warehouse space will be required each year if the Government meets its housing targets of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
National Planning Policy Framework (2024)
On the 12th December 2024, the adopted NPPF was published, setting out the Government's planning policies, including provisions in respect to industrial capacity.
The NPPF seeks to build a strong and competitive economy. Paragraph 86 states that policies should proactively encourage sustainable economic growth, having regard to the national industrial strategy. Policies should identify strategic sites for local and inward investment to match the strategy and to meet anticipated needs over the plan period. The wording seeks to encourage policies to pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics and seek to address potential barriers to investment. Policies should be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.
NPPF Paragraph 87 provides clear guidance on the different specific locational requirements of different sectors, including making provision for storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially when this is needed to support the supply chain, transport innovation and decarbonisation. It seeks to make provision for the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience.
In addition, NPPF Paragraph 127 requires policies and decisions to reflect changes in the demand for land and be informed by regular reviews of both the land allocated for development in plans, and of land availability.
Revised National Planning Policy Framework (2025)
On 16th December 2025, a revised version of the NPPF, alongside National Development Management Policies, were published for consultation until 10th March 2026. The consultation is a full 're-write' or 'overhaul' of the way in which the planning system operates.
Of particular interest, are the new policies which state that substantial weight should be given by the decision-maker to the economic benefits of proposals for commercial development.
Draft NPPF Policy E1 (Providing the conditions for long term economic growth) seeks to support investment and employment through development plans. Part 1 c. addresses meeting existing and anticipated needs of a modern economy, it further signals that this should relate to locational requirements. In essence, this Policy strengthens the support for allocating additional employment land relating to industries prevalent in the area, such as freight and logistics given the location within the Freeport East area.
Draft NPPF Policy E2 (Meeting the need for business land and premises) gives substantial weight to the economic benefits of commercial development; especially where this is in line with the economic vision and strategy for the area, the implementation of the Industrial Strategy, support improvements in freight and logistics. This Policy also alludes to considerations when demonstrating an unmet need including the undersupply of land or premises in the market and whether locational requirements are met by existing allocations in the development plan.
Draft NPPF Policy E3 (Freight and Logistics) supports the effective and efficient movement of goods and decision making should ensure there is good access to transport networks. The Policy is therefore supporting logistics employment uses accessible locations, the Site is located within 3km of the strategic road network and has onwards connections to international freight transport connections at Felixstowe Port and Stansted Airport.
The UK's Modern Industrial Strategy (2025)
The Government published The UK's Modern Industrial Strategy on 23 June 2025 setting out a 10- year plan to significantly increase business investment in eight growth-driving sectors (the IS-8), all of which rely on the Industrial and Logistics sector.
The Modern Industrial Strategy is the UK Governments 10-year plan to deliver the certainty and stability businesses need to invest in high growth sectors. Proposed measures of particular relevance to employment opportunities, which are intended to tackle the 'blockers', will include:
Tackling high industrial electricity costs and ensuring strategic investment projects (those creating high-quality jobs and bringing the greatest economic value) receive timely grid connections. New powers in the Planning and Infrastructure Bill will assist with amending regulatory processes and accelerating connections.
Removing planning barriers and providing backing to transformative infrastructure projects. This will include fast-tracking decisions on critical projects in the planning system and ensuring that the planning framework supports growth in the IS-8 (as reflected in the revised NPPF).
The Industrial Strategy sets out that investment and growth will be enabled through various measures including:
Proactively bringing forward more investible sites across the UK by attracting investment into Industrial Strategy Zones including Freeports.
Strengthening connections between and within city regions and clusters to ensure that more businesses are pulled into the orbit of the best UK talent, innovation, and academic collaboration, and more people have access to good jobs.
The Strategy also recognises the importance of the foundational industries to support the IS-8 sectors this includes the provision of industrial, freight and logistics, and notably the onwards connections to ports.
The Industrial Strategy describes itself as 'unashamedly place-based', recognising that stronger regional growth is critical for the competitiveness of the IS-8 and the resilience of the national economy. The Government therefore proposes to focus its efforts on the city regions and clusters with the highest potential to support the growth-driving sectors.
Freeport East
The UK Government designated Freeport East as a freeport through secondary legislation in December 2021. It was set up to catalyse economic growth in the Essex and Suffolk region through boosting international trade. Tax incentives and customs benefits are given to businesses operating in the area. Colchester sits within the area in close proximity to Ipswich, Felixstowe and Harwich Ports, with Felixstowe being the UK's largest container port. The sectors that the freeport focuses on are logistics, advanced manufacturing, renewable energy, digital and tech.
Summary of Strategic Planning Context
The above recent changes are key to the context of these representations, demonstrating that, nationally, there is a greater identified need for the delivery of employment land in the form of industrial and logistics space to ensure the country's economic growth remains strong, whilst also being diversified across different sectors, including logistics and manufacturing. The context clearly highlights the importance of the role industrial uses play at the strategic national level to support the economy.
Further to emphasise, minerals and construction materials play a fundamental part in this ambition and Tarmac are keen to see the release of further reserves locally to support infrastructure and growth delivery, but this Site represents an opportunity to add to the growth agenda with additional employment provision, either in parallel with the current activities or as they phase out over time.
Representations
Economic and Employment Opportunity - Site Promotion
We fully support the objective of draft Policy ST6 to provide a range of sites for employment uses to ensure jobs are accessible to new and existing communities across Colchester and we put forward the Site for employment allocation to assist with delivery to meet projected demand. The Site presents an excellent opportunity for employment use and intensification where there is a significant existing and future need for additional floorspace in a location that is ideally located for industrial and logistics uses. The need for additional employment space and the accessibility of the Site is discussed in more detail below.
Whilst the current expectation is for the Site to be restored following existing extraction activities, there is an excellent opportunity for the currently undesignated central southern portion of the Site to be developed for employment uses. This area falls outside of the Open Space and Local Wildlife Site designations, and comprises limited ecological value due to the activities that have taken place in this location. There is, therefore, an ideal plot of land entirely suitable for redevelopment to meet CCC's needs and objectives over the plan period whilst safeguarding the wider Site for restoration and biodiversity enhancements. The Site and its location is suitable for a range of quanta and typologies of employment uses. This includes floorspace for SME businesses who require smaller units alongside larger logistics and distribution facilities, making use of the Freeport East designations and connections to London and Stanstead Airport and providing local jobs for local people.
We note that the Site is located within a wider area where available land for development is very limited. The adjacent Colchester Zoo, scheduled monuments/ sites of archaeological importance, and ancient woodlands result in significant number of constraints on adjacent sites. Any land which is not constrained should therefore be optimised to protect sites of historic and natural interest whilst addressing identified needs. These wider constraints also benefit the developable area on the Site as they provide natural barriers to prevent the unconstrained sprawl of development from the built-up extent of Colchester. Part of the Site can therefore be developed without leading to unmanaged sprawl on land where there are no archaeological artifacts,
evidenced through the existing extraction activities taking place on the Site. Furthermore, there is potential to enhance the amenity and public realm focused restoration of land to the west of the Site (within Tarmac ownership) providing an equally strong new edge to the town.
Therefore, these representations consider that part of the Site presents an excellent opportunity for employment use which should be promoted through a site allocation within the new Local Plan, and we strongly recommend that the extent of the Strategic Biodiversity Area designation is reduced so that it does not limit the potential of the southern central area of the Site.
Economic and Employment Opportunity - Identified Need
In addition to the Site's potential to support employment uses, there is a clear identified need for additional employment floorspace over the plan period.
An Employment 'Demand' and 'Need' Technical Note, prepared by Marrons, is submitted in support of these Representations and included within Appendix II. The Note concludes that there is strong demand for industrial and logistics uses in Colchester and that the Colchester Employment Study (2025) and Preferred Options Local Plan are likely to underestimate the potential need.
The Note sets out that it is clear that there is limited supply in the area and that, of the supply that exists, there are few strategic sites suitable for large scale industrial and logistics occupiers. The Quarry is considered a suitable site for a broad range of industrial, and logistics uses and should therefore be viewed positively from an allocation perspective.
In addition, as set out above, an additional 25.64 million square feet of warehouse space will be required each year if the Government meets its housing target of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
Therefore, whilst we support draft Policy ST6's ambition to plan, monitor and manage the delivery of employment land to meet the projected demand up to 2041, we are concerned that the requirement of at least 41.7 ha of employment land significantly underestimates the actual existing and future demand for floorspace in the area, particularly due to the strategic nature of the area located within Freeport East with excellent connections to London and terminals, including Stansted Airport. There is, therefore, a pressing need to identify additional sites for employment uses and the Site provides an excellent opportunity to be allocated for Industrial and Logistics floorspace. The entirety of the Site should therefore not be limited through a blanket Strategic Biodiversity Area designation.
Notwithstanding this, we support the aspirations of draft Policy E2 which states that sites currently used for employment purposes in rural parts of Colchester will be safeguarded for appropriate economic uses to ensure local residents have access to local job opportunities to reduce the need to travel. The potential for the Site or part of the Site, which currently provides employment purposes to local people, to continue to deliver local jobs once the existing mineral extraction comes to an end should not be dismissed and there is an excellent opportunity for alternative employment uses to deliver significant benefits whilst addressing an identified need.
Economic and Employment Opportunity - Transport and Accessibility
Mode Transport have prepared a Transport Technical Note to accompany this representation. This note provides an initial assessment of the transport and highways conditions in relation to the Site promotion. The Site currently benefits from direct access onto Warren Lane and given its location it can take advantage of the strategic links (of regional and national importance) to the A12.
Adopted Local Plan Policy WCS (Transport in West Colchester) requires developments to contribute to a package of sustainable transport measures, such as active travel, public transport improvements and travel planning to promote sustainable travel. Policy WCS specifically includes reference to improvements at the Maldon Road/Warren Lane junction, of which development on the Site could make contribution to. Essex highways has also identified the Warren Lane/Maldon Road junction and seeks to upgrade to a 3-arm roundabout to reduce congestion.
The Draft Local Plan supports a vision-led transport planning approach, Policies PC2 (Active and Sustainable Travel) and Policy ST7 (Infrastructure Delivery and Impact Mitigation) promote developments being planned around safe and accessible active travel routes and the provision of appropriate infrastructure that serves the needs of the development. This vision-led approach is in line with Draft NPPF Policy TR1 (Vision-led approach to planning for transport) whereby sustainable transport should be considered at the earliest stages of plan-making.
Overall, the proposed employment use on the Site conforms with the emerging Colchester Local Plan Regulation 18 transport strategy and is well located regarding the existing sustainable transport connections and connections to the surrounding highway network. In any case, going forward a full transport assessment would be undertaken and any application would be supported by a Travel Plan.
Ecology and Biodiversity Significance
Within the Draft Preferred Options Local Plan Polices Map, the Site, in its entirety, has been designated as a Strategic Biodiversity Area (Stanway Gravel Pits). Draft Policy ST2 states that strategic areas that present the best opportunities for habitat creation and enhancement aimed at improving biodiversity are shown on the policies maps as 'strategic biodiversity areas'. These areas will be protected, and support will be given to strengthening and enhancing connections between habitats to improve their contribution to the biodiversity network.
The Strategic Biodiversity Assessment Uanuary 2025) forms part of the evidence base and identifies Area 6 'Stanway Gravel Pits' as an existing area of biodiversity significance, within which the Site sits. The Assessment notes that the area consists primarily of land which is subject to aggregate extraction and that its features provide ideal conditions for a range of scarce plants and invertebrates. It notes that all of the land has the potential to be restored and managed to provide diverse mosaics of open mosaic habitats, integrated with older or more structured new scrub and woodland habitats, post-industrial.
Whilst we support the aim of improving biodiversity and protecting areas which present the best opportunities for habitat creation, strengthening and enhancing connections between habitats, we do not support a blanket designation across the entirety of the Site, particularly when no evidence base has been undertaken to establish the potential opportunities for habitat creation on different parts of the Site and when no consideration has been given to how the Site can be used to address different priorities and needs.
As such we consider that there is no basis for a blanket designation across the whole of the site, particularly when it is being made without direct landowner engagement or consent and based on a limited evidence base. In our experience elsewhere, this approach can call into question the soundness of the Local Plan preparation.
Paragraph 16 of the National Planning Policy Framework (2024) emphasises that plans should be prepared positively through being aspirational but deliverable (16a) and be shaped by effective engagement with all stakeholders (16b). The Strategic Biodiversity Area may not be deliverable - Tarmac as the landowners can agree or disagree to proposals on their land that are not legally required or that have not been effectively communicated with them in dialogue with Colchester City Council. Therefore, an Inspector may view this designation as wholly unsound.
It is important to note that Tarmac is not against the principle of their landholdings being environmentally enhanced. However, what would be much more effective is to work with the landowner to appropriately assess those areas which might be appropriate for additional protection and enhancement (which could extend beyond the Site and into the owners other retained land), whilst still providing much needed additional employment space within the subject site to support the Local Plan preparation and adoption.
We therefore request a meeting to discuss this with you further. As part of ongoing discussions, we would also request an opportunity to undertake ecological assessments to enable us to work with the LPA and develop a strategy for the Site and its allocation so that the Local Plan can define a more appropriate Strategic Biodiversity Area to maximise enhancements and benefits whilst making efficient use of part of the Site that offers very little in terms of ecology.
We therefore object to the extent of the designation and recommend that the Strategic Biodiversity Area is reduced to match the extents of the Open Space and Local Wildlife Sites designations. This will enable biodiversity enhancements to be maximised on the northern portion of the Site whilst enabling a smaller portion to be allocated for employment use to address future employment space needs. The redevelopment of part of the Site would enable detailed analysis of the land to understand how biodiversity and connections can be protected and enhanced across the land as a whole without limiting the Site's potential and only securing moderate benefits through restoration of the land.
Residential Potential
Whilst we note that these representations seek to promote part of the Site for employment uses, it should be acknowledged that the Site could also play an important role in the future delivery of homes for Colchester. We note that draft Policy STS states that the Council will maintain a sufficient supply of deliverable and developable sites to provide for at least five years' worth of housing on a rolling basis, plus an appropriate buffer, and the Plan should also look ahead and plan for the long-term delivery of identified needs.
Whilst the Site is currently located outside of the Colchester settlement boundary, it lies in close proximity to the Fiveways Fruit Farm site where planning permission (ref. 182220) has been granted for 420 homes as part of the wider Stanway Growth Area. The Site could therefore form part of a natural extension to the built-up area of Colchester in the future which may be required to meet additional future demand and the Site's potential should not be limited through the proposed Strategic Biodiversity Area designation covering the entirety of the Site.
Summary
Based on the matters outlined in these representations, The Site offers a strong opportunity to meet employment needs not only within the borough, but also across the region and at a national level.
In light of recent shifts in national planning legislation and policy, and following the election of the Labour Government, there is a demonstrable need to allocate suitable land for industrial and logistics employment uses. Labour's commitment to rapidly advancing and prioritising the national industrial strategy provides a strong foundation for the promotion and allocation of high quality development sites. Given its highly sustainable location and its potential to contribute meaningfully to the objectives of the industrial strategy, this Site should be allocated for employment use and the extent of the Strategic Biodiversity Area should be reduced to ensure the Site's potential contribution to identified needs is not inappropriately limited.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
We would appreciate it if you could provide confirmation that these representations have been received. Please let us know if you have any questions.
Attachments:
- FULL SUBMISSION (16.39 MB)
Comment
Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025
Policy E2: Economic Development in Rural Areas and the Countryside
Representation ID: 14129
Received: 14/01/2026
Respondent: Tarmac Ltd
Agent: Aisling O`Kane
Support aspirations of draft Policy E2 which states that sites currently used for employment purposes in rural parts of Colchester will be safeguarded for appropriate economic uses to ensure local residents have access to local job opportunities to reduce the need to travel. The potential for the Site (East of Warren Lane) or part of it which currently provides employment purposes to local people, to continue to deliver local jobs once the existing mineral extraction comes to an end should not be dismissed. There is an excellent opportunity for alternative employment uses to deliver significant benefits whilst addressing identified need.
We write on behalf of our client, Tarmac Trading Limited ('Tarmac'}, to provide representations to Colchester City Council's ('CCC') Preferred Options Local Plan Regulation 18 Consultation. These representations are made in relation to Land east of Warren Lane, Colchester, CO3 0NN ('the Site'), as shown on the Site Location Plan included within Appendix I.
Supporting Information
In addition to this Letter, the representations are supported by the following:
- Appendix I - Site Location Plan;
- Appendix II - Employment Demand and Need Technical Note, prepared by Marrons;
- Appendix Ill - Transport Appraisal, prepared by Mode Transport Planning.
Introduction
These representations are submitted in relation to the Preferred Options Local Plan Regulation 18 Consultation 2025 to 1) promote the Site for employment uses; and 2) object to the extent of the proposed Strategic Biodiversity Area (Stanway Gravel Pits) that covers the entirety of the Site.
The representations set out details of the Site and surrounding context, the strategic planning context, the reasons why the Site is suitable for employment opportunity and should therefore be allocated for development within the Local Plan and the recent policy and legislative changes that have impacted the principle and quantum of development on the Site.
The representations then investigate the following elements related to the Site and its potential continued employment use: economic benefits, transport and accessibility, ecology, and residential potential.
Tarmac is the UK's leading sustainable building materials and construction solutions business, with over 100,000 acres of land within their control. Tarmac has significant land holdings to the south west of Colchester, including the Site to which these representations relates.
Tarmac is aware of the Call for Sites consultation which was undertaken between 20 October 2023 and 5January 2024. At the time of the consultation, Tarmac was unable to submit a representation for the Site due to uncertainty around the timescales and use of the Site for mineral extraction in the medium to long term. Consequently, the Site has not been assessed within the Strategic Land Availability Assessment ('SLAA') published February 2025.
Subsequently, following the Call for Sites consultation, Tarmac has prepared a clear strategy and timeline for the Site, enabling representations to be made at this stage to promote the Site for employment use to assist with the Local Plan preparation and help CCC set a sound plan and vision for growth. Notably, recent national legislative and policy changes in planning, including the Planning and Infrastructure Act, the adoption of the National Industrial Strategy and the revised consultation National Planning Policy Framework ('NPPF'), further accelerate the need for employment activity and floorspace, and in particular, investment into the industrial and logistics sectors.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
Site and Surrounding Context
The Site is located within the administrative boundary of CCC. The Site is approximately 5km to the south west of Colchester City Centre and circa 150m to the south of the settlement boundary of Colchester. Colchester Railway Station is circa 5.5km to the north east of the Site, with Marks Tey Railway Station Circa 4km to the north west.
The Site is bound by Maldon Road (B1022) to the south, with Colchester Zoo and the 'Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm' scheduled monument beyond. Warren Lane bounds the west of the Site with the Bellhouse Landfill beyond which is also in Tarmac ownership and subject to its own restoration plan. A public bridleway bounds the east of the Site, with the 'Gosbecks Iron Age and Romano-British Site' scheduled monument beyond. To the north there is some mineral extraction land currently being restored and beyond is the Fiveways Fruit Farm which has part detailed, part outline permission (ref. 182220) for 420 homes within the settlement boundary of Colchester.
The Site extends to approximately 94ha and comprises gravel quarry works with associated plant and machinery set amongst lagoons and wooded areas across the Site. The southern boundary of the Site is lined with trees and shrubs. There is one Public Right of Way ('PRoW') through the Site that joins up to Maldon Road to the south of the Site to Warren Lane to the north of the Site.
The Site is ideally located circa 3km from London Road (A12), providing excellent connections to London and Freeport East as well as the wider road network beyond. The Colchester Zoo bus stop is located immediately adjacent to the south of the Site and is served by bus routes onwards to Colchester City Centre and beyond.
The scheduled monuments are not within the Site but do lie within 10m of the boundary to the east and within 10m of part of the boundary to the south. The Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm scheduled monument list entry number is 1490583. The Gosbecks Iron Age and Romano-British site list entry number is 1002180.
There are no listed buildings or conservation areas within the Site. Circa 150m south of the Site is the Grade II* listed Church of All Saints, this is currently set within Colchester Zoo. Circa 220m north east of the Site is the Grade II listed Wiseman's Farmhouse, a private residential property.
There are two areas of Ancient Woodland surrounding the Site; Gol Grove/Hanging Wood west of the Site and Butchers Wood south east of the Site.
Minerals and Waste Position
The Site is currently operated as a mineral extraction and processing facility with ancillary operations. Extraction has largely been completed on the Site with restoration activities progressing. Ongoing processing operations are utilising material being brought in from adjacent areas which will likely be exhausted in the short to medium term (as early as 2030). Recent planning activity (ref. ESS/13/25/COL) has aligned operational planning permissions with this potential end date with restoration (part acid grassland and part woodland) as part of the overall restoration scheme to follow on.
The existing mineral operations are of the utmost importance in providing vital foundation materials to infrastructure and other development projects in the local area, but there is the potential for the site to offer additional development opportunities, either in parallel with ongoing operations, or to follow on from them as they phase out over whatever timescale plays out.
The Site should therefore be considered for an alternative employment use for the medium/long term within the Local Plan.
Essex County Council's ('ECC') Mineral Local Plan ('MLP') was adopted in July 2014. ECC's Minerals and Waste Development Scheme was last updated in November 2019, with the last consultation being the Regulation 18 consultation on the Minerals Local Plan Review in April 2021. Tarmac is promoting an extension extraction site to the MLP to the south west which would continue their operations in the Colchester area and these await further progress on the MLP.
Adopted Local Plan
The adopted Colchester Local Plan up to 2033 is split into two sections, with Section 1 adopted in February 2021 and Section 2 adopted in July 2022.
Within the adopted Local Plan, the northern and western portions of the Site (as outlined in the Site Local Plan) are designated as Public Open Space and there are five Local Wildlife Sites dispersed throughout the Site. There is an area of undesignated land within the central southern portion of the Site.
Emerging Local Plan Preparation
These representations are made to the current Preferred Options Local Plan (Regulation 18) consultation forming part of the preparation of a new Local Plan for Colchester. The Plan will set the strategy for growth in Colchester up to 2041 and once adopted, will replace existing Local Plan Policies. CCC's Local Development Scheme states that submission of the Regulation 19 Plan and Summary of comments will be made in August/ September of 2026.
The Local Plan is supported by an evidence base and supporting documents of which the following are of particular relevance to the Site and its potential for employment use:
Employment Study (February 2025);
Strategic Biodiversity Assessment Uanuary 2025);
Strategic Land Availability Assessment (SLAA): Site Assessments Report Stage 2 (February
2025).
The CCC Preferred Options Local Plan consultation document, and interactive policies map, confirms that, in addition to the existing Open Space and Local Wildlife Site designations, it is proposed to designate the Site as a Local Landscape Character Assessment area and a Strategic Biodiversity Area (Stanway Gravel Pits). An extract of the interactive policy map for the Preferred Options Local Plan is shown in Figure 1.
Figure 1: Interactive Policy Map Extract taken from CCC website (SEE ATTACHMENT)
As set out within the Introduction, these representations seek to promote the Site for employment uses and object to the proposed extent of the Strategic Biodiversity Area (Stanway Gravel Pits) that covers the Site. This is guided by the strategic planning context and the identified need as set out below.
Strategic Planning Context
Planning and Infrastructure Act 2025
The Planning and Infrastructure Bill received Royal Assent on the 18th December 2025. The Act sets rules for infrastructure and planning, introduces a nature restoration levy for developers run by Natural England, updates powers for development corporations and compulsory land purchase, establishes environmental outcomes reports, and covers related matters. The Act is central to the Government's plan to get Britain building again and deliver economic growth. It seeks to speed up and streamline the delivery of new homes and critical infrastructure, supporting the delivery of the Government's Plan for Change milestones of building 1.5 million homes in England and fast tracking 150 planning decisions on major economic infrastructure projects by the end of this Parliament.
The Planning and Infrastructure Act requires the preparation of Spatial Development Strategies ('SDS'). This follows the local government reorganisation driven from the English Devolution White Paper. The vision for Colchester includes three unitary authorities which will form Greater Essex. Greater Essex has already been announced as part of the Devolution Priority Programme and the Government is minded to establish a Mayoral Combined County Authority. CCC will then become part of the North Essex Unitary. The SDS puts a stronger emphasis on delivering housing, employment space and infrastructure at a sub-regional scale. It is, therefore, anticipated that following the adoption of the current draft Local Plan, the next Development Plan for the Site will cover a different spatial areas and be in the form of a Local Plan and a SDS.
We note that housing delivery is directly linked to increased demand for logistics space, with each new home requiring an additional 69 square feet of warehouse space to support its distribution needs (The British Property Federation's What Warehousing Where? Report). Therefore, an additional
25.64 million square feet of warehouse space will be required each year if the Government meets its housing targets of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
National Planning Policy Framework (2024)
On the 12th December 2024, the adopted NPPF was published, setting out the Government's planning policies, including provisions in respect to industrial capacity.
The NPPF seeks to build a strong and competitive economy. Paragraph 86 states that policies should proactively encourage sustainable economic growth, having regard to the national industrial strategy. Policies should identify strategic sites for local and inward investment to match the strategy and to meet anticipated needs over the plan period. The wording seeks to encourage policies to pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics and seek to address potential barriers to investment. Policies should be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.
NPPF Paragraph 87 provides clear guidance on the different specific locational requirements of different sectors, including making provision for storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially when this is needed to support the supply chain, transport innovation and decarbonisation. It seeks to make provision for the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience.
In addition, NPPF Paragraph 127 requires policies and decisions to reflect changes in the demand for land and be informed by regular reviews of both the land allocated for development in plans, and of land availability.
Revised National Planning Policy Framework (2025)
On 16th December 2025, a revised version of the NPPF, alongside National Development Management Policies, were published for consultation until 10th March 2026. The consultation is a full 're-write' or 'overhaul' of the way in which the planning system operates.
Of particular interest, are the new policies which state that substantial weight should be given by the decision-maker to the economic benefits of proposals for commercial development.
Draft NPPF Policy E1 (Providing the conditions for long term economic growth) seeks to support investment and employment through development plans. Part 1 c. addresses meeting existing and anticipated needs of a modern economy, it further signals that this should relate to locational requirements. In essence, this Policy strengthens the support for allocating additional employment land relating to industries prevalent in the area, such as freight and logistics given the location within the Freeport East area.
Draft NPPF Policy E2 (Meeting the need for business land and premises) gives substantial weight to the economic benefits of commercial development; especially where this is in line with the economic vision and strategy for the area, the implementation of the Industrial Strategy, support improvements in freight and logistics. This Policy also alludes to considerations when demonstrating an unmet need including the undersupply of land or premises in the market and whether locational requirements are met by existing allocations in the development plan.
Draft NPPF Policy E3 (Freight and Logistics) supports the effective and efficient movement of goods and decision making should ensure there is good access to transport networks. The Policy is therefore supporting logistics employment uses accessible locations, the Site is located within 3km of the strategic road network and has onwards connections to international freight transport connections at Felixstowe Port and Stansted Airport.
The UK's Modern Industrial Strategy (2025)
The Government published The UK's Modern Industrial Strategy on 23 June 2025 setting out a 10- year plan to significantly increase business investment in eight growth-driving sectors (the IS-8), all of which rely on the Industrial and Logistics sector.
The Modern Industrial Strategy is the UK Governments 10-year plan to deliver the certainty and stability businesses need to invest in high growth sectors. Proposed measures of particular relevance to employment opportunities, which are intended to tackle the 'blockers', will include:
Tackling high industrial electricity costs and ensuring strategic investment projects (those creating high-quality jobs and bringing the greatest economic value) receive timely grid connections. New powers in the Planning and Infrastructure Bill will assist with amending regulatory processes and accelerating connections.
Removing planning barriers and providing backing to transformative infrastructure projects. This will include fast-tracking decisions on critical projects in the planning system and ensuring that the planning framework supports growth in the IS-8 (as reflected in the revised NPPF).
The Industrial Strategy sets out that investment and growth will be enabled through various measures including:
Proactively bringing forward more investible sites across the UK by attracting investment into Industrial Strategy Zones including Freeports.
Strengthening connections between and within city regions and clusters to ensure that more businesses are pulled into the orbit of the best UK talent, innovation, and academic collaboration, and more people have access to good jobs.
The Strategy also recognises the importance of the foundational industries to support the IS-8 sectors this includes the provision of industrial, freight and logistics, and notably the onwards connections to ports.
The Industrial Strategy describes itself as 'unashamedly place-based', recognising that stronger regional growth is critical for the competitiveness of the IS-8 and the resilience of the national economy. The Government therefore proposes to focus its efforts on the city regions and clusters with the highest potential to support the growth-driving sectors.
Freeport East
The UK Government designated Freeport East as a freeport through secondary legislation in December 2021. It was set up to catalyse economic growth in the Essex and Suffolk region through boosting international trade. Tax incentives and customs benefits are given to businesses operating in the area. Colchester sits within the area in close proximity to Ipswich, Felixstowe and Harwich Ports, with Felixstowe being the UK's largest container port. The sectors that the freeport focuses on are logistics, advanced manufacturing, renewable energy, digital and tech.
Summary of Strategic Planning Context
The above recent changes are key to the context of these representations, demonstrating that, nationally, there is a greater identified need for the delivery of employment land in the form of industrial and logistics space to ensure the country's economic growth remains strong, whilst also being diversified across different sectors, including logistics and manufacturing. The context clearly highlights the importance of the role industrial uses play at the strategic national level to support the economy.
Further to emphasise, minerals and construction materials play a fundamental part in this ambition and Tarmac are keen to see the release of further reserves locally to support infrastructure and growth delivery, but this Site represents an opportunity to add to the growth agenda with additional employment provision, either in parallel with the current activities or as they phase out over time.
Representations
Economic and Employment Opportunity - Site Promotion
We fully support the objective of draft Policy ST6 to provide a range of sites for employment uses to ensure jobs are accessible to new and existing communities across Colchester and we put forward the Site for employment allocation to assist with delivery to meet projected demand. The Site presents an excellent opportunity for employment use and intensification where there is a significant existing and future need for additional floorspace in a location that is ideally located for industrial and logistics uses. The need for additional employment space and the accessibility of the Site is discussed in more detail below.
Whilst the current expectation is for the Site to be restored following existing extraction activities, there is an excellent opportunity for the currently undesignated central southern portion of the Site to be developed for employment uses. This area falls outside of the Open Space and Local Wildlife Site designations, and comprises limited ecological value due to the activities that have taken place in this location. There is, therefore, an ideal plot of land entirely suitable for redevelopment to meet CCC's needs and objectives over the plan period whilst safeguarding the wider Site for restoration and biodiversity enhancements. The Site and its location is suitable for a range of quanta and typologies of employment uses. This includes floorspace for SME businesses who require smaller units alongside larger logistics and distribution facilities, making use of the Freeport East designations and connections to London and Stanstead Airport and providing local jobs for local people.
We note that the Site is located within a wider area where available land for development is very limited. The adjacent Colchester Zoo, scheduled monuments/ sites of archaeological importance, and ancient woodlands result in significant number of constraints on adjacent sites. Any land which is not constrained should therefore be optimised to protect sites of historic and natural interest whilst addressing identified needs. These wider constraints also benefit the developable area on the Site as they provide natural barriers to prevent the unconstrained sprawl of development from the built-up extent of Colchester. Part of the Site can therefore be developed without leading to unmanaged sprawl on land where there are no archaeological artifacts,
evidenced through the existing extraction activities taking place on the Site. Furthermore, there is potential to enhance the amenity and public realm focused restoration of land to the west of the Site (within Tarmac ownership) providing an equally strong new edge to the town.
Therefore, these representations consider that part of the Site presents an excellent opportunity for employment use which should be promoted through a site allocation within the new Local Plan, and we strongly recommend that the extent of the Strategic Biodiversity Area designation is reduced so that it does not limit the potential of the southern central area of the Site.
Economic and Employment Opportunity - Identified Need
In addition to the Site's potential to support employment uses, there is a clear identified need for additional employment floorspace over the plan period.
An Employment 'Demand' and 'Need' Technical Note, prepared by Marrons, is submitted in support of these Representations and included within Appendix II. The Note concludes that there is strong demand for industrial and logistics uses in Colchester and that the Colchester Employment Study (2025) and Preferred Options Local Plan are likely to underestimate the potential need.
The Note sets out that it is clear that there is limited supply in the area and that, of the supply that exists, there are few strategic sites suitable for large scale industrial and logistics occupiers. The Quarry is considered a suitable site for a broad range of industrial, and logistics uses and should therefore be viewed positively from an allocation perspective.
In addition, as set out above, an additional 25.64 million square feet of warehouse space will be required each year if the Government meets its housing target of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
Therefore, whilst we support draft Policy ST6's ambition to plan, monitor and manage the delivery of employment land to meet the projected demand up to 2041, we are concerned that the requirement of at least 41.7 ha of employment land significantly underestimates the actual existing and future demand for floorspace in the area, particularly due to the strategic nature of the area located within Freeport East with excellent connections to London and terminals, including Stansted Airport. There is, therefore, a pressing need to identify additional sites for employment uses and the Site provides an excellent opportunity to be allocated for Industrial and Logistics floorspace. The entirety of the Site should therefore not be limited through a blanket Strategic Biodiversity Area designation.
Notwithstanding this, we support the aspirations of draft Policy E2 which states that sites currently used for employment purposes in rural parts of Colchester will be safeguarded for appropriate economic uses to ensure local residents have access to local job opportunities to reduce the need to travel. The potential for the Site or part of the Site, which currently provides employment purposes to local people, to continue to deliver local jobs once the existing mineral extraction comes to an end should not be dismissed and there is an excellent opportunity for alternative employment uses to deliver significant benefits whilst addressing an identified need.
Economic and Employment Opportunity - Transport and Accessibility
Mode Transport have prepared a Transport Technical Note to accompany this representation. This note provides an initial assessment of the transport and highways conditions in relation to the Site promotion. The Site currently benefits from direct access onto Warren Lane and given its location it can take advantage of the strategic links (of regional and national importance) to the A12.
Adopted Local Plan Policy WCS (Transport in West Colchester) requires developments to contribute to a package of sustainable transport measures, such as active travel, public transport improvements and travel planning to promote sustainable travel. Policy WCS specifically includes reference to improvements at the Maldon Road/Warren Lane junction, of which development on the Site could make contribution to. Essex highways has also identified the Warren Lane/Maldon Road junction and seeks to upgrade to a 3-arm roundabout to reduce congestion.
The Draft Local Plan supports a vision-led transport planning approach, Policies PC2 (Active and Sustainable Travel) and Policy ST7 (Infrastructure Delivery and Impact Mitigation) promote developments being planned around safe and accessible active travel routes and the provision of appropriate infrastructure that serves the needs of the development. This vision-led approach is in line with Draft NPPF Policy TR1 (Vision-led approach to planning for transport) whereby sustainable transport should be considered at the earliest stages of plan-making.
Overall, the proposed employment use on the Site conforms with the emerging Colchester Local Plan Regulation 18 transport strategy and is well located regarding the existing sustainable transport connections and connections to the surrounding highway network. In any case, going forward a full transport assessment would be undertaken and any application would be supported by a Travel Plan.
Ecology and Biodiversity Significance
Within the Draft Preferred Options Local Plan Polices Map, the Site, in its entirety, has been designated as a Strategic Biodiversity Area (Stanway Gravel Pits). Draft Policy ST2 states that strategic areas that present the best opportunities for habitat creation and enhancement aimed at improving biodiversity are shown on the policies maps as 'strategic biodiversity areas'. These areas will be protected, and support will be given to strengthening and enhancing connections between habitats to improve their contribution to the biodiversity network.
The Strategic Biodiversity Assessment Uanuary 2025) forms part of the evidence base and identifies Area 6 'Stanway Gravel Pits' as an existing area of biodiversity significance, within which the Site sits. The Assessment notes that the area consists primarily of land which is subject to aggregate extraction and that its features provide ideal conditions for a range of scarce plants and invertebrates. It notes that all of the land has the potential to be restored and managed to provide diverse mosaics of open mosaic habitats, integrated with older or more structured new scrub and woodland habitats, post-industrial.
Whilst we support the aim of improving biodiversity and protecting areas which present the best opportunities for habitat creation, strengthening and enhancing connections between habitats, we do not support a blanket designation across the entirety of the Site, particularly when no evidence base has been undertaken to establish the potential opportunities for habitat creation on different parts of the Site and when no consideration has been given to how the Site can be used to address different priorities and needs.
As such we consider that there is no basis for a blanket designation across the whole of the site, particularly when it is being made without direct landowner engagement or consent and based on a limited evidence base. In our experience elsewhere, this approach can call into question the soundness of the Local Plan preparation.
Paragraph 16 of the National Planning Policy Framework (2024) emphasises that plans should be prepared positively through being aspirational but deliverable (16a) and be shaped by effective engagement with all stakeholders (16b). The Strategic Biodiversity Area may not be deliverable - Tarmac as the landowners can agree or disagree to proposals on their land that are not legally required or that have not been effectively communicated with them in dialogue with Colchester City Council. Therefore, an Inspector may view this designation as wholly unsound.
It is important to note that Tarmac is not against the principle of their landholdings being environmentally enhanced. However, what would be much more effective is to work with the landowner to appropriately assess those areas which might be appropriate for additional protection and enhancement (which could extend beyond the Site and into the owners other retained land), whilst still providing much needed additional employment space within the subject site to support the Local Plan preparation and adoption.
We therefore request a meeting to discuss this with you further. As part of ongoing discussions, we would also request an opportunity to undertake ecological assessments to enable us to work with the LPA and develop a strategy for the Site and its allocation so that the Local Plan can define a more appropriate Strategic Biodiversity Area to maximise enhancements and benefits whilst making efficient use of part of the Site that offers very little in terms of ecology.
We therefore object to the extent of the designation and recommend that the Strategic Biodiversity Area is reduced to match the extents of the Open Space and Local Wildlife Sites designations. This will enable biodiversity enhancements to be maximised on the northern portion of the Site whilst enabling a smaller portion to be allocated for employment use to address future employment space needs. The redevelopment of part of the Site would enable detailed analysis of the land to understand how biodiversity and connections can be protected and enhanced across the land as a whole without limiting the Site's potential and only securing moderate benefits through restoration of the land.
Residential Potential
Whilst we note that these representations seek to promote part of the Site for employment uses, it should be acknowledged that the Site could also play an important role in the future delivery of homes for Colchester. We note that draft Policy STS states that the Council will maintain a sufficient supply of deliverable and developable sites to provide for at least five years' worth of housing on a rolling basis, plus an appropriate buffer, and the Plan should also look ahead and plan for the long-term delivery of identified needs.
Whilst the Site is currently located outside of the Colchester settlement boundary, it lies in close proximity to the Fiveways Fruit Farm site where planning permission (ref. 182220) has been granted for 420 homes as part of the wider Stanway Growth Area. The Site could therefore form part of a natural extension to the built-up area of Colchester in the future which may be required to meet additional future demand and the Site's potential should not be limited through the proposed Strategic Biodiversity Area designation covering the entirety of the Site.
Summary
Based on the matters outlined in these representations, The Site offers a strong opportunity to meet employment needs not only within the borough, but also across the region and at a national level.
In light of recent shifts in national planning legislation and policy, and following the election of the Labour Government, there is a demonstrable need to allocate suitable land for industrial and logistics employment uses. Labour's commitment to rapidly advancing and prioritising the national industrial strategy provides a strong foundation for the promotion and allocation of high quality development sites. Given its highly sustainable location and its potential to contribute meaningfully to the objectives of the industrial strategy, this Site should be allocated for employment use and the extent of the Strategic Biodiversity Area should be reduced to ensure the Site's potential contribution to identified needs is not inappropriately limited.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
We would appreciate it if you could provide confirmation that these representations have been received. Please let us know if you have any questions.
Attachments:
- FULL SUBMISSION (16.39 MB)
Comment
Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025
Policy ST2: Environment and the Green Network and Waterways
Representation ID: 14130
Received: 14/01/2026
Respondent: Tarmac Ltd
Agent: Aisling O`Kane
The Strategic Biodiversity Assessment identifies Area 6 'Stanway Gravel Pits' as an existing area of biodiversity significance, within which the Site sits.
we do not support a blanket designation across the entirety of the Site. Recommend the Strategic Biodiversity Area is reduced to match the extents of the Open Space and Local Wildlife Sites designations.
We therefore request a meeting to discuss this with you further. As part of ongoing discussions, we would also request an opportunity to undertake ecological assessments to enable us to work with the LPA and develop a strategy for the Site and its allocation.
We write on behalf of our client, Tarmac Trading Limited ('Tarmac'}, to provide representations to Colchester City Council's ('CCC') Preferred Options Local Plan Regulation 18 Consultation. These representations are made in relation to Land east of Warren Lane, Colchester, CO3 0NN ('the Site'), as shown on the Site Location Plan included within Appendix I.
Supporting Information
In addition to this Letter, the representations are supported by the following:
- Appendix I - Site Location Plan;
- Appendix II - Employment Demand and Need Technical Note, prepared by Marrons;
- Appendix Ill - Transport Appraisal, prepared by Mode Transport Planning.
Introduction
These representations are submitted in relation to the Preferred Options Local Plan Regulation 18 Consultation 2025 to 1) promote the Site for employment uses; and 2) object to the extent of the proposed Strategic Biodiversity Area (Stanway Gravel Pits) that covers the entirety of the Site.
The representations set out details of the Site and surrounding context, the strategic planning context, the reasons why the Site is suitable for employment opportunity and should therefore be allocated for development within the Local Plan and the recent policy and legislative changes that have impacted the principle and quantum of development on the Site.
The representations then investigate the following elements related to the Site and its potential continued employment use: economic benefits, transport and accessibility, ecology, and residential potential.
Tarmac is the UK's leading sustainable building materials and construction solutions business, with over 100,000 acres of land within their control. Tarmac has significant land holdings to the south west of Colchester, including the Site to which these representations relates.
Tarmac is aware of the Call for Sites consultation which was undertaken between 20 October 2023 and 5January 2024. At the time of the consultation, Tarmac was unable to submit a representation for the Site due to uncertainty around the timescales and use of the Site for mineral extraction in the medium to long term. Consequently, the Site has not been assessed within the Strategic Land Availability Assessment ('SLAA') published February 2025.
Subsequently, following the Call for Sites consultation, Tarmac has prepared a clear strategy and timeline for the Site, enabling representations to be made at this stage to promote the Site for employment use to assist with the Local Plan preparation and help CCC set a sound plan and vision for growth. Notably, recent national legislative and policy changes in planning, including the Planning and Infrastructure Act, the adoption of the National Industrial Strategy and the revised consultation National Planning Policy Framework ('NPPF'), further accelerate the need for employment activity and floorspace, and in particular, investment into the industrial and logistics sectors.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
Site and Surrounding Context
The Site is located within the administrative boundary of CCC. The Site is approximately 5km to the south west of Colchester City Centre and circa 150m to the south of the settlement boundary of Colchester. Colchester Railway Station is circa 5.5km to the north east of the Site, with Marks Tey Railway Station Circa 4km to the north west.
The Site is bound by Maldon Road (B1022) to the south, with Colchester Zoo and the 'Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm' scheduled monument beyond. Warren Lane bounds the west of the Site with the Bellhouse Landfill beyond which is also in Tarmac ownership and subject to its own restoration plan. A public bridleway bounds the east of the Site, with the 'Gosbecks Iron Age and Romano-British Site' scheduled monument beyond. To the north there is some mineral extraction land currently being restored and beyond is the Fiveways Fruit Farm which has part detailed, part outline permission (ref. 182220) for 420 homes within the settlement boundary of Colchester.
The Site extends to approximately 94ha and comprises gravel quarry works with associated plant and machinery set amongst lagoons and wooded areas across the Site. The southern boundary of the Site is lined with trees and shrubs. There is one Public Right of Way ('PRoW') through the Site that joins up to Maldon Road to the south of the Site to Warren Lane to the north of the Site.
The Site is ideally located circa 3km from London Road (A12), providing excellent connections to London and Freeport East as well as the wider road network beyond. The Colchester Zoo bus stop is located immediately adjacent to the south of the Site and is served by bus routes onwards to Colchester City Centre and beyond.
The scheduled monuments are not within the Site but do lie within 10m of the boundary to the east and within 10m of part of the boundary to the south. The Roman Practice Camp and Late Iron Age and Roman remains east of Stanway Hall Farm scheduled monument list entry number is 1490583. The Gosbecks Iron Age and Romano-British site list entry number is 1002180.
There are no listed buildings or conservation areas within the Site. Circa 150m south of the Site is the Grade II* listed Church of All Saints, this is currently set within Colchester Zoo. Circa 220m north east of the Site is the Grade II listed Wiseman's Farmhouse, a private residential property.
There are two areas of Ancient Woodland surrounding the Site; Gol Grove/Hanging Wood west of the Site and Butchers Wood south east of the Site.
Minerals and Waste Position
The Site is currently operated as a mineral extraction and processing facility with ancillary operations. Extraction has largely been completed on the Site with restoration activities progressing. Ongoing processing operations are utilising material being brought in from adjacent areas which will likely be exhausted in the short to medium term (as early as 2030). Recent planning activity (ref. ESS/13/25/COL) has aligned operational planning permissions with this potential end date with restoration (part acid grassland and part woodland) as part of the overall restoration scheme to follow on.
The existing mineral operations are of the utmost importance in providing vital foundation materials to infrastructure and other development projects in the local area, but there is the potential for the site to offer additional development opportunities, either in parallel with ongoing operations, or to follow on from them as they phase out over whatever timescale plays out.
The Site should therefore be considered for an alternative employment use for the medium/long term within the Local Plan.
Essex County Council's ('ECC') Mineral Local Plan ('MLP') was adopted in July 2014. ECC's Minerals and Waste Development Scheme was last updated in November 2019, with the last consultation being the Regulation 18 consultation on the Minerals Local Plan Review in April 2021. Tarmac is promoting an extension extraction site to the MLP to the south west which would continue their operations in the Colchester area and these await further progress on the MLP.
Adopted Local Plan
The adopted Colchester Local Plan up to 2033 is split into two sections, with Section 1 adopted in February 2021 and Section 2 adopted in July 2022.
Within the adopted Local Plan, the northern and western portions of the Site (as outlined in the Site Local Plan) are designated as Public Open Space and there are five Local Wildlife Sites dispersed throughout the Site. There is an area of undesignated land within the central southern portion of the Site.
Emerging Local Plan Preparation
These representations are made to the current Preferred Options Local Plan (Regulation 18) consultation forming part of the preparation of a new Local Plan for Colchester. The Plan will set the strategy for growth in Colchester up to 2041 and once adopted, will replace existing Local Plan Policies. CCC's Local Development Scheme states that submission of the Regulation 19 Plan and Summary of comments will be made in August/ September of 2026.
The Local Plan is supported by an evidence base and supporting documents of which the following are of particular relevance to the Site and its potential for employment use:
Employment Study (February 2025);
Strategic Biodiversity Assessment Uanuary 2025);
Strategic Land Availability Assessment (SLAA): Site Assessments Report Stage 2 (February
2025).
The CCC Preferred Options Local Plan consultation document, and interactive policies map, confirms that, in addition to the existing Open Space and Local Wildlife Site designations, it is proposed to designate the Site as a Local Landscape Character Assessment area and a Strategic Biodiversity Area (Stanway Gravel Pits). An extract of the interactive policy map for the Preferred Options Local Plan is shown in Figure 1.
Figure 1: Interactive Policy Map Extract taken from CCC website (SEE ATTACHMENT)
As set out within the Introduction, these representations seek to promote the Site for employment uses and object to the proposed extent of the Strategic Biodiversity Area (Stanway Gravel Pits) that covers the Site. This is guided by the strategic planning context and the identified need as set out below.
Strategic Planning Context
Planning and Infrastructure Act 2025
The Planning and Infrastructure Bill received Royal Assent on the 18th December 2025. The Act sets rules for infrastructure and planning, introduces a nature restoration levy for developers run by Natural England, updates powers for development corporations and compulsory land purchase, establishes environmental outcomes reports, and covers related matters. The Act is central to the Government's plan to get Britain building again and deliver economic growth. It seeks to speed up and streamline the delivery of new homes and critical infrastructure, supporting the delivery of the Government's Plan for Change milestones of building 1.5 million homes in England and fast tracking 150 planning decisions on major economic infrastructure projects by the end of this Parliament.
The Planning and Infrastructure Act requires the preparation of Spatial Development Strategies ('SDS'). This follows the local government reorganisation driven from the English Devolution White Paper. The vision for Colchester includes three unitary authorities which will form Greater Essex. Greater Essex has already been announced as part of the Devolution Priority Programme and the Government is minded to establish a Mayoral Combined County Authority. CCC will then become part of the North Essex Unitary. The SDS puts a stronger emphasis on delivering housing, employment space and infrastructure at a sub-regional scale. It is, therefore, anticipated that following the adoption of the current draft Local Plan, the next Development Plan for the Site will cover a different spatial areas and be in the form of a Local Plan and a SDS.
We note that housing delivery is directly linked to increased demand for logistics space, with each new home requiring an additional 69 square feet of warehouse space to support its distribution needs (The British Property Federation's What Warehousing Where? Report). Therefore, an additional
25.64 million square feet of warehouse space will be required each year if the Government meets its housing targets of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
National Planning Policy Framework (2024)
On the 12th December 2024, the adopted NPPF was published, setting out the Government's planning policies, including provisions in respect to industrial capacity.
The NPPF seeks to build a strong and competitive economy. Paragraph 86 states that policies should proactively encourage sustainable economic growth, having regard to the national industrial strategy. Policies should identify strategic sites for local and inward investment to match the strategy and to meet anticipated needs over the plan period. The wording seeks to encourage policies to pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics and seek to address potential barriers to investment. Policies should be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.
NPPF Paragraph 87 provides clear guidance on the different specific locational requirements of different sectors, including making provision for storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially when this is needed to support the supply chain, transport innovation and decarbonisation. It seeks to make provision for the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience.
In addition, NPPF Paragraph 127 requires policies and decisions to reflect changes in the demand for land and be informed by regular reviews of both the land allocated for development in plans, and of land availability.
Revised National Planning Policy Framework (2025)
On 16th December 2025, a revised version of the NPPF, alongside National Development Management Policies, were published for consultation until 10th March 2026. The consultation is a full 're-write' or 'overhaul' of the way in which the planning system operates.
Of particular interest, are the new policies which state that substantial weight should be given by the decision-maker to the economic benefits of proposals for commercial development.
Draft NPPF Policy E1 (Providing the conditions for long term economic growth) seeks to support investment and employment through development plans. Part 1 c. addresses meeting existing and anticipated needs of a modern economy, it further signals that this should relate to locational requirements. In essence, this Policy strengthens the support for allocating additional employment land relating to industries prevalent in the area, such as freight and logistics given the location within the Freeport East area.
Draft NPPF Policy E2 (Meeting the need for business land and premises) gives substantial weight to the economic benefits of commercial development; especially where this is in line with the economic vision and strategy for the area, the implementation of the Industrial Strategy, support improvements in freight and logistics. This Policy also alludes to considerations when demonstrating an unmet need including the undersupply of land or premises in the market and whether locational requirements are met by existing allocations in the development plan.
Draft NPPF Policy E3 (Freight and Logistics) supports the effective and efficient movement of goods and decision making should ensure there is good access to transport networks. The Policy is therefore supporting logistics employment uses accessible locations, the Site is located within 3km of the strategic road network and has onwards connections to international freight transport connections at Felixstowe Port and Stansted Airport.
The UK's Modern Industrial Strategy (2025)
The Government published The UK's Modern Industrial Strategy on 23 June 2025 setting out a 10- year plan to significantly increase business investment in eight growth-driving sectors (the IS-8), all of which rely on the Industrial and Logistics sector.
The Modern Industrial Strategy is the UK Governments 10-year plan to deliver the certainty and stability businesses need to invest in high growth sectors. Proposed measures of particular relevance to employment opportunities, which are intended to tackle the 'blockers', will include:
Tackling high industrial electricity costs and ensuring strategic investment projects (those creating high-quality jobs and bringing the greatest economic value) receive timely grid connections. New powers in the Planning and Infrastructure Bill will assist with amending regulatory processes and accelerating connections.
Removing planning barriers and providing backing to transformative infrastructure projects. This will include fast-tracking decisions on critical projects in the planning system and ensuring that the planning framework supports growth in the IS-8 (as reflected in the revised NPPF).
The Industrial Strategy sets out that investment and growth will be enabled through various measures including:
Proactively bringing forward more investible sites across the UK by attracting investment into Industrial Strategy Zones including Freeports.
Strengthening connections between and within city regions and clusters to ensure that more businesses are pulled into the orbit of the best UK talent, innovation, and academic collaboration, and more people have access to good jobs.
The Strategy also recognises the importance of the foundational industries to support the IS-8 sectors this includes the provision of industrial, freight and logistics, and notably the onwards connections to ports.
The Industrial Strategy describes itself as 'unashamedly place-based', recognising that stronger regional growth is critical for the competitiveness of the IS-8 and the resilience of the national economy. The Government therefore proposes to focus its efforts on the city regions and clusters with the highest potential to support the growth-driving sectors.
Freeport East
The UK Government designated Freeport East as a freeport through secondary legislation in December 2021. It was set up to catalyse economic growth in the Essex and Suffolk region through boosting international trade. Tax incentives and customs benefits are given to businesses operating in the area. Colchester sits within the area in close proximity to Ipswich, Felixstowe and Harwich Ports, with Felixstowe being the UK's largest container port. The sectors that the freeport focuses on are logistics, advanced manufacturing, renewable energy, digital and tech.
Summary of Strategic Planning Context
The above recent changes are key to the context of these representations, demonstrating that, nationally, there is a greater identified need for the delivery of employment land in the form of industrial and logistics space to ensure the country's economic growth remains strong, whilst also being diversified across different sectors, including logistics and manufacturing. The context clearly highlights the importance of the role industrial uses play at the strategic national level to support the economy.
Further to emphasise, minerals and construction materials play a fundamental part in this ambition and Tarmac are keen to see the release of further reserves locally to support infrastructure and growth delivery, but this Site represents an opportunity to add to the growth agenda with additional employment provision, either in parallel with the current activities or as they phase out over time.
Representations
Economic and Employment Opportunity - Site Promotion
We fully support the objective of draft Policy ST6 to provide a range of sites for employment uses to ensure jobs are accessible to new and existing communities across Colchester and we put forward the Site for employment allocation to assist with delivery to meet projected demand. The Site presents an excellent opportunity for employment use and intensification where there is a significant existing and future need for additional floorspace in a location that is ideally located for industrial and logistics uses. The need for additional employment space and the accessibility of the Site is discussed in more detail below.
Whilst the current expectation is for the Site to be restored following existing extraction activities, there is an excellent opportunity for the currently undesignated central southern portion of the Site to be developed for employment uses. This area falls outside of the Open Space and Local Wildlife Site designations, and comprises limited ecological value due to the activities that have taken place in this location. There is, therefore, an ideal plot of land entirely suitable for redevelopment to meet CCC's needs and objectives over the plan period whilst safeguarding the wider Site for restoration and biodiversity enhancements. The Site and its location is suitable for a range of quanta and typologies of employment uses. This includes floorspace for SME businesses who require smaller units alongside larger logistics and distribution facilities, making use of the Freeport East designations and connections to London and Stanstead Airport and providing local jobs for local people.
We note that the Site is located within a wider area where available land for development is very limited. The adjacent Colchester Zoo, scheduled monuments/ sites of archaeological importance, and ancient woodlands result in significant number of constraints on adjacent sites. Any land which is not constrained should therefore be optimised to protect sites of historic and natural interest whilst addressing identified needs. These wider constraints also benefit the developable area on the Site as they provide natural barriers to prevent the unconstrained sprawl of development from the built-up extent of Colchester. Part of the Site can therefore be developed without leading to unmanaged sprawl on land where there are no archaeological artifacts,
evidenced through the existing extraction activities taking place on the Site. Furthermore, there is potential to enhance the amenity and public realm focused restoration of land to the west of the Site (within Tarmac ownership) providing an equally strong new edge to the town.
Therefore, these representations consider that part of the Site presents an excellent opportunity for employment use which should be promoted through a site allocation within the new Local Plan, and we strongly recommend that the extent of the Strategic Biodiversity Area designation is reduced so that it does not limit the potential of the southern central area of the Site.
Economic and Employment Opportunity - Identified Need
In addition to the Site's potential to support employment uses, there is a clear identified need for additional employment floorspace over the plan period.
An Employment 'Demand' and 'Need' Technical Note, prepared by Marrons, is submitted in support of these Representations and included within Appendix II. The Note concludes that there is strong demand for industrial and logistics uses in Colchester and that the Colchester Employment Study (2025) and Preferred Options Local Plan are likely to underestimate the potential need.
The Note sets out that it is clear that there is limited supply in the area and that, of the supply that exists, there are few strategic sites suitable for large scale industrial and logistics occupiers. The Quarry is considered a suitable site for a broad range of industrial, and logistics uses and should therefore be viewed positively from an allocation perspective.
In addition, as set out above, an additional 25.64 million square feet of warehouse space will be required each year if the Government meets its housing target of 371,541 new homes annually, highlighting that the changes sought by the Planning and Infrastructure Act 2025 will result in fundamental changes to objectively assessed needs, including for industrial and logistics floorspace.
Therefore, whilst we support draft Policy ST6's ambition to plan, monitor and manage the delivery of employment land to meet the projected demand up to 2041, we are concerned that the requirement of at least 41.7 ha of employment land significantly underestimates the actual existing and future demand for floorspace in the area, particularly due to the strategic nature of the area located within Freeport East with excellent connections to London and terminals, including Stansted Airport. There is, therefore, a pressing need to identify additional sites for employment uses and the Site provides an excellent opportunity to be allocated for Industrial and Logistics floorspace. The entirety of the Site should therefore not be limited through a blanket Strategic Biodiversity Area designation.
Notwithstanding this, we support the aspirations of draft Policy E2 which states that sites currently used for employment purposes in rural parts of Colchester will be safeguarded for appropriate economic uses to ensure local residents have access to local job opportunities to reduce the need to travel. The potential for the Site or part of the Site, which currently provides employment purposes to local people, to continue to deliver local jobs once the existing mineral extraction comes to an end should not be dismissed and there is an excellent opportunity for alternative employment uses to deliver significant benefits whilst addressing an identified need.
Economic and Employment Opportunity - Transport and Accessibility
Mode Transport have prepared a Transport Technical Note to accompany this representation. This note provides an initial assessment of the transport and highways conditions in relation to the Site promotion. The Site currently benefits from direct access onto Warren Lane and given its location it can take advantage of the strategic links (of regional and national importance) to the A12.
Adopted Local Plan Policy WCS (Transport in West Colchester) requires developments to contribute to a package of sustainable transport measures, such as active travel, public transport improvements and travel planning to promote sustainable travel. Policy WCS specifically includes reference to improvements at the Maldon Road/Warren Lane junction, of which development on the Site could make contribution to. Essex highways has also identified the Warren Lane/Maldon Road junction and seeks to upgrade to a 3-arm roundabout to reduce congestion.
The Draft Local Plan supports a vision-led transport planning approach, Policies PC2 (Active and Sustainable Travel) and Policy ST7 (Infrastructure Delivery and Impact Mitigation) promote developments being planned around safe and accessible active travel routes and the provision of appropriate infrastructure that serves the needs of the development. This vision-led approach is in line with Draft NPPF Policy TR1 (Vision-led approach to planning for transport) whereby sustainable transport should be considered at the earliest stages of plan-making.
Overall, the proposed employment use on the Site conforms with the emerging Colchester Local Plan Regulation 18 transport strategy and is well located regarding the existing sustainable transport connections and connections to the surrounding highway network. In any case, going forward a full transport assessment would be undertaken and any application would be supported by a Travel Plan.
Ecology and Biodiversity Significance
Within the Draft Preferred Options Local Plan Polices Map, the Site, in its entirety, has been designated as a Strategic Biodiversity Area (Stanway Gravel Pits). Draft Policy ST2 states that strategic areas that present the best opportunities for habitat creation and enhancement aimed at improving biodiversity are shown on the policies maps as 'strategic biodiversity areas'. These areas will be protected, and support will be given to strengthening and enhancing connections between habitats to improve their contribution to the biodiversity network.
The Strategic Biodiversity Assessment Uanuary 2025) forms part of the evidence base and identifies Area 6 'Stanway Gravel Pits' as an existing area of biodiversity significance, within which the Site sits. The Assessment notes that the area consists primarily of land which is subject to aggregate extraction and that its features provide ideal conditions for a range of scarce plants and invertebrates. It notes that all of the land has the potential to be restored and managed to provide diverse mosaics of open mosaic habitats, integrated with older or more structured new scrub and woodland habitats, post-industrial.
Whilst we support the aim of improving biodiversity and protecting areas which present the best opportunities for habitat creation, strengthening and enhancing connections between habitats, we do not support a blanket designation across the entirety of the Site, particularly when no evidence base has been undertaken to establish the potential opportunities for habitat creation on different parts of the Site and when no consideration has been given to how the Site can be used to address different priorities and needs.
As such we consider that there is no basis for a blanket designation across the whole of the site, particularly when it is being made without direct landowner engagement or consent and based on a limited evidence base. In our experience elsewhere, this approach can call into question the soundness of the Local Plan preparation.
Paragraph 16 of the National Planning Policy Framework (2024) emphasises that plans should be prepared positively through being aspirational but deliverable (16a) and be shaped by effective engagement with all stakeholders (16b). The Strategic Biodiversity Area may not be deliverable - Tarmac as the landowners can agree or disagree to proposals on their land that are not legally required or that have not been effectively communicated with them in dialogue with Colchester City Council. Therefore, an Inspector may view this designation as wholly unsound.
It is important to note that Tarmac is not against the principle of their landholdings being environmentally enhanced. However, what would be much more effective is to work with the landowner to appropriately assess those areas which might be appropriate for additional protection and enhancement (which could extend beyond the Site and into the owners other retained land), whilst still providing much needed additional employment space within the subject site to support the Local Plan preparation and adoption.
We therefore request a meeting to discuss this with you further. As part of ongoing discussions, we would also request an opportunity to undertake ecological assessments to enable us to work with the LPA and develop a strategy for the Site and its allocation so that the Local Plan can define a more appropriate Strategic Biodiversity Area to maximise enhancements and benefits whilst making efficient use of part of the Site that offers very little in terms of ecology.
We therefore object to the extent of the designation and recommend that the Strategic Biodiversity Area is reduced to match the extents of the Open Space and Local Wildlife Sites designations. This will enable biodiversity enhancements to be maximised on the northern portion of the Site whilst enabling a smaller portion to be allocated for employment use to address future employment space needs. The redevelopment of part of the Site would enable detailed analysis of the land to understand how biodiversity and connections can be protected and enhanced across the land as a whole without limiting the Site's potential and only securing moderate benefits through restoration of the land.
Residential Potential
Whilst we note that these representations seek to promote part of the Site for employment uses, it should be acknowledged that the Site could also play an important role in the future delivery of homes for Colchester. We note that draft Policy STS states that the Council will maintain a sufficient supply of deliverable and developable sites to provide for at least five years' worth of housing on a rolling basis, plus an appropriate buffer, and the Plan should also look ahead and plan for the long-term delivery of identified needs.
Whilst the Site is currently located outside of the Colchester settlement boundary, it lies in close proximity to the Fiveways Fruit Farm site where planning permission (ref. 182220) has been granted for 420 homes as part of the wider Stanway Growth Area. The Site could therefore form part of a natural extension to the built-up area of Colchester in the future which may be required to meet additional future demand and the Site's potential should not be limited through the proposed Strategic Biodiversity Area designation covering the entirety of the Site.
Summary
Based on the matters outlined in these representations, The Site offers a strong opportunity to meet employment needs not only within the borough, but also across the region and at a national level.
In light of recent shifts in national planning legislation and policy, and following the election of the Labour Government, there is a demonstrable need to allocate suitable land for industrial and logistics employment uses. Labour's commitment to rapidly advancing and prioritising the national industrial strategy provides a strong foundation for the promotion and allocation of high quality development sites. Given its highly sustainable location and its potential to contribute meaningfully to the objectives of the industrial strategy, this Site should be allocated for employment use and the extent of the Strategic Biodiversity Area should be reduced to ensure the Site's potential contribution to identified needs is not inappropriately limited.
We welcome the opportunity to submit representations through the Local Plan Review process in relation to the Site and request a meeting with CCC to discuss this with you so that we can present our findings prior to the Preferred Options Local Plan Regulation 18 before progressing any further.
We would appreciate it if you could provide confirmation that these representations have been received. Please let us know if you have any questions.
Attachments:
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