Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Spencer Planning Limited acts on behalf of Mr & Mrs Tim Knighton, the owners of 6.67 hectares (ha) of agricultural land to the northeast of Coach Road, Great Horkesley, as set out on the accompanying Site Location Plan (drawing no. X21482-01b). This land benefits from an existing access onto Coach Road.

Our clients support the Vision at paragraph 2.19 of the Local Plan Regulation 18 document, including its recognition that the local authority area will grow and change, and that this brings with it opportunity.

Our clients support the proposed Spatial Strategy at Policy ST3 of the Local Plan Regulation 18 document, including its aim to direct growth across Colchester with an appropriate level of development allocated within the large, medium (including at Great Horkesley) and some small settlements. Our clients also support the recognition in the Local Plan that growth needs must be balanced against the need to protect and enhance biodiversity, the surrounding landscape and heritage assets.

It is encouraging to read that Colchester City Council (CCC) intends to plan for its latest local housing needs in full. Notably these were increased by the Government as part of the December 2024 changes to the National Planning Policy Framework (NPPF) and the Standard Housing Method.

Having said that, the housing supply currently identified in the Regulation 18 document (21,106) only exceeds the minimum local housing need (20,800) by 306 dwellings. This equates to a buffer of just 1.5% and is well below the 10%+ buffers that most Essex authorities generally allow for in their local plans. A buffer of 1.5% will provide very little flexibility to handle changing circumstances.

Furthermore, paragraph 22 in the NPPF expects strategic policies to look ahead over a minimum 15-year period from adoption. The Colchester Local Development Scheme (March 2025) indicates that the new Local Plan is unlikely to be adopted until Spring 2027, at the earliest. As a result the plan period end date set out in Policy ST5 should be extended from 2041 until at least 2042.

In summary this means that:

• The minimum local housing need figure in the Local Plan should be increased by at least another 1,300 homes, from 20,800 to 22,100 homes, to allow for Local Plan adoption in 2027 and a minimum 15-year plan period from 2027 to 2042; and
• The total housing supply in the Local Plan would be more robust if it were increased by another 3,204 homes, from 21,106 to 24,310 homes, to allow for the increased local housing need figure above and also to provide a more meaningful supply buffer of 10% over the adjusted local housing need figure.

These changes should help to ensure that the new Local Plan is ‘positively prepared’ (i.e. provides a strategy which seeks to meet the area’s objectively assessed needs), ‘justified’ (i.e. provides an appropriate strategy taking into account the reasonable alternatives) and ‘consistent with national policy’ (i.e. enables the delivery of sustainable development in accordance with the policies in the NPPF), as set out in paragraph 36 of the NPPF.

This policy sets out that all development must be supported by the provision of infrastructure, services and facilities. It explains that where a development proposal requires additional infrastructure capacity to be deemed acceptable, mitigation measures must be agreed with CCC, which may include: financial contributions towards new or expanded infrastructure; on-site provision of new facilities; off-site capacity improvement works; and/or, the provision of land. The policy also sets out that at the time of adoption of the new Local Plan, every allocation will be considered to be viable, based on information provided to CCC.

Notably this information includes the Colchester Whole Plan Viability Assessment prepared by Newmark in October 2025.

Although our clients are broadly supportive of Policy ST7, they respectfully request that CCC instructs an independent audit of Newmark’s Viability Assessment to investigate the following areas of potential concern:

• Page 50 of the Full Appraisals for Colchester Whole Plan Viability Assessment report suggests that total planning obligations (i.e. s106 costs and any CIL) for the 400 dwelling allocation on the land north of Coach Road (i.e. the allocation in Policy PP34) could total £31.62m. This equates to approximately £79k per dwelling and is a very substantial figure, far in excess of that usually experienced in Colchester or Essex. For example, the Bloor Homes site for 150 dwellings on the southern part of this allocation was approved by CCC’s planning committee on 27th November 2025 with planning obligations totalling approximately £2.85m or circa £19k per dwelling, according to the committee report. With this in mind, how have Newmark justified a figure of approximately £79k per dwelling for the allocation as a whole?

• Page 50 of the Full Appraisals for Colchester Whole Plan Viability Assessment report concludes that the land north of Coach Road is viable even with planning contributions of approximately £79k per dwelling. However, this would represent an unprecedented level of planning obligations and Spencer Planning is not aware of any residential development being found viable and actually delivered at or near this figure in Essex. Does CCC have any practical examples of where this has worked successfully?

• The Benchmark Land Value (BLV) used in page 50 of the assessment is £3.04m. The allocation as a whole extends to approximately 13.7 hectares (ha), resulting in a BLV of circa £222k per ha. However, Table 1 in the Colchester Whole Plan Viability Assessment report suggests that Existing Use Value (EUV) for greenfield sites is just below £31k per ha. This means that Newmark believes that agricultural landowner’s will sell their land for development at just seven times EUV. A minimum factor of at least 10 times EUV should be used to establish BLV and even that is widely accepted to be modest and perhaps not acceptable in many cases, with many landowners looking to achieve 20+ times EUV when selling land for residential development.

• The ‘Total Cost (exc. Finance)’ of development on Page 50 of the Full Appraisals for Colchester Whole Plan Viability Assessment report is stated as £110.73m. However, the sum of the actual figures listed above this total comes to £118.13m. Circa £8m appears to be missing from the total, with no explanation why. Furthermore, the ‘Development Value Summary’ refers to a completely different ‘Total Cost’ of £109.59m which – even after ‘Finance’ costs are removed – does not match either of the aforementioned figures. These errors are a consistent issue throughout the Full Appraisals for Colchester Whole Plan Viability Assessment report.

Overall it is encouraging that CCC is undertaking this detailed level of viability work at a relatively early stage of the plan-making process. However, for the reasons set out above, further refinement and auditing of the figures will be necessary in due course to ensure there is sufficient justification, accuracy and realism in any information that is ultimately presented to an inspector when the new Local Plan reaches Examination in Public (EiP).

Mr & Mrs Knighton own 6.67 hectares (ha) of agricultural land to the northeast of Coach Road, Great Horkesley, as set out on the accompanying Site Location Plan (drawing no. X21482-01b), which benefits from an existing access onto Coach Road. This land immediately abuts the approved Bloor Homes development for 150 homes (application ref. 250545) to the southeast and forms part of the wider draft allocation for approximately 400 homes on the western edge of Great Horkesley village, as set out in Policy PP34 of the Local Plan document.

Notably Appendix E of the CCC’s Sustainability Appraisal (February 2025) concludes that: “The development of this site [i.e. the Bloor site] and the adjacent site [i.e. Mr & Mrs Knighton’s land] would form a logical extension to Great Horkesley when compared against alternatives. The site is well connected to services and facilities within the village.”

Furthermore, paragraph 2.98 of the Sustainability Appraisal confirms that Great Horkesley is just 0.6 km from the urban edge of Colchester and that there are a range of services and facilities within the Village. These include but are not limited to a nursery and primary school, village hall, village green and children’s play equipment, church, post office and convenience store, public house and petrol station. Great Horkesley has good public transport links for a semi-rural settlement and is served by existing bus routes on Coach Road and Nayland Road that link the village to Bury St Edmunds, Sudbury and Colchester, including Colchester railway station. In summary the Village is a sustainable location for proportionate future growth.

The accompanying Masterplan (drawing no. 792-FGA-ZZ-XX-D-A-1010) demonstrates how a residential-led development could be accommodated in this location while respecting the layout, form and scale of the existing village and adjoining Bloor development, and while minimising impacts on the character and appearance of the wider countryside beyond.

The layout is structured around maximising exposure to green corridors, with development parcels that predominantly face outwards and overlook areas of new public open space, existing greenspace or new tree-lined streets, which are a primary urban design consideration in contemporary landscape-led schemes. Greenspace from the recently approved Bloor development to the south will be continued northwards into the centre of this site, thereby providing a variety of amenity, biodiversity and surface water drainage benefits in a central park and creating an attractive place to live.

New pedestrian and cycle routes leading through the structured green spaces will provide excellent connectivity from within the site, through the adjacent Bloor development and on towards the existing nursery, primary school and other facilities in the village.

It is noted that CCC and Essex County Council (ECC) currently prefer this site to be accessed exclusively through the Bloor development. Although that may be feasible, subject to detailed discussions with Bloor, there are also good reasons to plan for a vehicular access directly from Coach Road to the southwest by either retaining and making use of the existing access at the site’s southern-most corner or by relocating this access midway along the site’s frontage with Coach Road. Ensuring that Mr & Mrs Knighton’s land retains its own independent access will provide the following benefits:

(i) Enable the site to come forward sooner and therefore support the delivery of new homes in the all-important first five years of the plan period. Whereas if CCC and ECC insist that vehicular access must be derived from the Bloor site, development on Mr & Mrs Knighton’s land could be delayed by several years until Bloor have built and handed over an adoptable highway to ECC.
(ii) Lead to better living conditions and residential amenity for new residents on the Bloor site, who would otherwise have vehicles from up to 200 additional dwellings passing their homes each day.
(iii) Help to promote sustainable modes of travel from Mr & Mrs Knighton’s land, by providing a more direct foot and cycle path through the Bloor development to the village amenities to the east and a longer vehicular route to the southwest via Coach Road.
(iv) Better access and contingency for emergency services, with scope for a main access from Coach Road and a secondary or emergency-only access through the Bloor development. This will be safer than the whole allocation being served solely from one point of access on the Bloor development.
(v) Delivery of an access that addresses the majority of objections to the Bloor planning application, which were concerned with the close proximity of the Bloor access and the entrance to the primary school. A separate access to the southwest of Mr & Mrs Knighton’s land offers an opportunity to reduce the volume of vehicle movements near the school, particularly for those travelling from the allocation towards West Bergholt (via Nayland Road) or towards Sudbury (via Old House Road).

Intermodal Transportation advise that a standard priority junction can be provided onto Coach Road in accordance with relevant Highway Guidance and with adequate visibility splays in both directions. In summary the accompanying Masterplan (drawing no. 792-FGA-ZZ-XX-D-A-1010) provides the flexibility to access Mr & Mrs Knighton’s land through the Bloor site and / or from an independent access direct from Coach Road. The latter could involve retaining and making use of the existing access at the site’s southern-most corner or relocating this access midway along the site’s frontage with Coach Road.

A single main vehicular loop within the site will support an efficient use of land and distribution of block and plot frontages, with development focussed around seven double-fronted residential parcels which face predominantly to the northwest and southeast and two single-fronted residential parcels which face to the southeast. All of these parcels are roughly rectangular in shape.

Existing trees and hedgerows comprise the site's key green assets, in terms of habitats and biodiversity, and will be retained and reinforced with new planting wherever possible.

Approximately 5.79 ha of Mr & Mrs Knighton’s land is identified for built form including in the region of 170 to 200 new dwellings (with 30% affordable homes) at a net residential density of approximately 30 to 35 dwellings per ha (dph), new streets and an equipped play area for children.

The landowners envisage that the new homes will be built to the latest design and sustainability standards, including but not limited to net zero carbon (in accordance with Policies NZ1 and NZ2), achieving greater water efficiencies of at most 80 litres per person per day (Policy NZ3), a mix of market, affordable home ownership, affordable rent and older people housing (in accordance with Policy H1) and 2% self and custom build housing (Policy H6).

The remaining 0.88 ha of the site will be dedicated to public open and greenspace, SuDS to attenuate surface water on-site and areas to achieve a minimum 10% net gain in biodiversity, as required by the Environment Act.

Section 3.3.11 of the Colchester Water Cycle Study (February 2025) acknowledges that Great Horkesley is served by the West Bergholt Water Recycling Centre (WRC), which is at capacity and has limited scope to serve additional allocations when combined with existing commitments. However, the report also recommends that an 80 litre per person per day (l/p/d) per capita consumption (PCC) limit be imposed for the allocated sites in this catchment to facilitate the delivery of sites early in the plan period and that developers demonstrate they have agreed available capacity at the WRC and associated sewer network with Anglian Water Services prior to submitting planning applications. Development at this site will be designed to comply with these recommendations and the necessary demonstration of capacity will be provided prior to a planning application being made.

In summary Mr & Mrs Knighton’s land is available, achievable and suitable for a proportionate extension to the village and can deliver benefits for the local community such as: (i) new market, affordable and self / custom build homes to meet identified needs; (ii) new public open space and an equipped play area; and, (iii) enhanced pedestrian and cycle access between the existing village, the adjacent Bloor development and the site.

New residential-led development in this location could also provide planning contributions to enhance capacity at the local primary and secondary schools, health centre, village hall and / or other local community facilities.

Therefore Mr & Mrs Knighton support the allocation of this land, and the adjoining Bloor development, for approximately 400 homes in Policy PP34 of the Local Plan document. Mr & Mrs Knighton also welcome the opportunity to prepare a collaborative and comprehensive masterplan for the entire site allocation, working alongside the Council, Bloor Homes and local stakeholders.