Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

1. Introduction
This representation is submitted on behalf of Winstred Hundred Parish Council (WHPC) following an extensive consultation process with local residents, particularly those living in Peldon.
WHPC notes that Colchester City Council (CCC) has proposed an allocation of 25 dwellings in Peldon and has indicated Site PP49 (Land at St Ives Road) as its preferred location.

Overwhelmingly, Peldon residents oppose a 25-house development in the village.
WHPC considers this allocation to be unsound and inconsistent with national and local policy for the following reasons, as tested against the requirements of Paragraph 36 of the December 2024 issue of the National Planning Policy Framework (NPPF 36):

• Procedurally Unsound (Not Justified): CCC has failed the 'justified' test (NPPF 36b). There is no robust evidence base demonstrating this is the most appropriate and proportionate strategy when considered against reasonable alternatives, particularly in the absence of a proven, locally defined housing need for open-market housing.
• Fundamentally Unsound (Not Effective/Deliverable): The site faces severe, unmitigated constraints related to infrastructure capacity (water/sewage), highway safety (NPPF 115), accessibility, and cumulative impacts that render the site undeliverable and ineffective within the plan period (NPPF 36c).

• Not Consistent with National Policy – The allocation conflicts fundamentally with core NPPF principles of sustainable development (NPPF 7, 8 & 12), protecting sensitive landscapes (NPPF 20d,156, 187, 189 - 193), minimising flood risk (NPPF 170), and the requirement to direct housing to locations well-served by sustainable transport (NPPF 89, 109).

2. Planning Policy Context

2.1 Settlement Hierarchy
Under the adopted Colchester Local Plan (Section 2, 2022), Peldon is designated as a “small settlement” under Policy ST3.
Such settlements are expected to accommodate only very limited growth, and mainly through:
• small infill development,
• rural exception sites,
• housing that demonstrably meets local need.
A 25-unit estate-style allocation is incompatible with the role a settlement and contradicts CCC’s settlement hierarchy under Policies ST3 & ST4, which direct growth to sustainable settlements with services such as Colchester, Tiptree, and Wivenhoe.

2.2 Scale of Change

Peldon comprises approximately 220 dwellings, of which around 50 lie outside the main settlement.
A 25-house development would therefore represent:
• 11% growth across the entire village;
• 15% growth within the main settlement.
For a small rural village with no services, no pavements, no lighting, limited public transport, and limited infrastructure, this scale of development is disproportionate and inappropriate.
The WHPC’s 2024 Housing Needs Survey provides robust, up-to-date evidence of local sentiment and actual need:
• Residents support small-scale development (4-8 homes) only if it is primarily affordable housing for local people.
• Crucially, the majority of respondents (57%) opposed the further development of houses for sale on the open market.

The proposed 25 open-market units on Site PP49 thus fundamentally fail the 'justified' test of soundness; they do not address a locally defined need and ignore the clear preference for smaller, affordable rural exception sites. Such smaller sites are actively encouraged by NPPF 83, 73d & 76.

2.3 Village Character

Peldon’s distinctive form is ribbon development around the Peldon Triangle.
A cul-de-sac estate would significantly and adversely alter the settlement character, contrary to:
• NPPF 133 (local character and distinctiveness),
• Local Plan Policies EN1 – EN4 (landscape protection), and
• Policy ST3 (small-scale, appropriate growth).

3. Key Objections Summary

WHPC maintains that the PP49 allocation is unsound due to a failure to address fundamental, unmitigated constraints that render the site unsustainable and incompatible with both the NPPF and the Local Plan.
a. Highway and Accessibility Constraints
St Ives Road and its connecting network are:
• narrow,
• partially single-track,
• lacking continuous pavements,
• poorly lit (in fact unlit),
• possessing substandard visibility splays at the Church Road junction,
• used heavily by farm traffic, delivery vehicles, school traffic, and buses.

The proposed allocation is Unsound as the evidence required to demonstrate safe and suitable access (NPPF 96b & 115) has not been provided, and the projected impact would trigger the national test for refusal (NPPF 116) on both grounds.

• Failure to Satisfy NPPF 115b: …it should be ensured that "safe and suitable access […] for all users." The Council has failed to secure a Transport Assessment (TA) or a formal Road Safety Audit (RSA) from the developer, which are prerequisite steps taken for comparable allocated sites in the Local Plan (e.g., Abberton/Langenhoe).

• Failure of the "Significant/unacceptable Impact" Test (NPPF 115d & 116): The projected volume of vehicle movements from 25 dwellings accessing St Ives Road and its junction with Church Road, combined with existing agricultural and commuter traffic, will result in substantial residual cumulative impacts on highway safety. In the absence of a TA, the Council cannot substantiate that the residual impact is not severe.

• Citable Evidence Challenge: WHPC requests that the Council formally publish the data from the Essex Highways Collision Data Map (TraffWeb) for the St Ives Road/Church Road junction and 0.75km along each direction of both roads. The lack of prior fatal or serious injury accidents does not negate the requirement for a new TA to assess the future risk posed by the intensification of use on substandard roads.
• Car Dependency: The site is wholly car-dependent, conflicting with NPPF 109 (directing development to sustainable locations).

b. Infrastructure Capacity
The village has:
• no primary school,
• no shop,
• no GP or dentist,
• limited foul drainage and surface water capacity,
• poor broadband choice,
• no sustainable transport options.
Local services already experience high demand, oversubscription, or inaccessibility.
Residents report recurrent wastewater issues and Anglian Water outages during heavy rainfall.
The allocation is therefore not effective under NPPF 35, as infrastructure capacity cannot support this level of development.

c. Environmental and Landscape Impact
The site forms part of open countryside and contributes to Peldon’s rural landscape setting. Development would:
• erode the open character of the Peldon Triangle,
• harm views across the Mersea Flats,
• disrupt habitats for priority species (nightingales, bats, raptors, songbirds), and therefore should not be supported according to Policy EN1
• remove or damage mature hedgerows and wildlife corridors.

The site lies within the Coastal Protection Belt, where Policy LC3 seeks to restrict development that harms sensitive landscapes. In particular, paragraph 6.11 of the consultation document states that development (with the exception of householder applications) will only be supported where it can be demonstrated that it requires a coastal location due to the nature of the use and is located within the developed area of the coast.

Crucially, the site is within the zone of influence for the internationally designated Abberton Reservoir SPA/Ramsar/SSSI. All development in this zone is subject to the Habitats Regulations Assessment (HRA) process regarding potential recreational disturbance, water quality impacts, and nutrient neutrality.
CCC has failed to provide a robust HRA screening or assessment demonstrating that this allocation will not have an Adverse Effect on Integrity (AEoI) of the protected site. This omission renders the plan unsound as it breaches the Conservation of Habitats and Species Regulations 2019 (as amended).

d. Flood Risk and Drainage
Environment Agency mapping shows:
• surface-water flow paths through the site,
• localised ponding,
• runoff flowing downslope toward St Ives Road.
The site is not sequentially preferable (NPPF 172–177).
Anglian Water’s local networks are already under strain.

e. Unsustainable Settlement Role
Peldon has:
• no services (shops, medical facilities, schools)
• limited employment areas,
• no safe pedestrian network,
• poor transport,
• no capacity for additional school or medical demand.

A development of this scale would create an unsustainable commuter settlement, contrary to:
• NPPF 7 (Sustainable development) summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs,
• NPPF 110 (directing development to sustainable locations),
• Local Plan Policies ST3, ST4.

4. Heritage Considerations

The wider setting of Peldon includes heritage assets such as St Mary’s Church (listed) and traditional rural lanes. The open countryside around the village contributes to their setting.
Even though PP49 is outside the immediate vicinity of listed buildings, the landscape setting forms an important component of local heritage.
Under NPPF 207–210, harm to a heritage setting must be given great weight, even if less than substantial.

5. Ecological and Habitat Impacts

The Peldon Triangle and surrounding hedgerows are habitats for:
• red-listed nightingales,
• owls, buzzards, kestrels,
• bats,
• badgers, foxes, deer,
• a wide range of songbirds.

The open countryside around Peldon also forms part of the ecological zone connected to Abberton Reservoir SPA/Ramsar, meaning:
• any development must be screened for HRA,
• recreational disturbance contributions would be required,
• cumulative effects must be assessed.
No such assessment has been provided.

6. Cumulative Impact

Substantial development is already taking place in:
• Abberton,
• Mersea Island,
• Tiptree
• nearby villages.

Key cumulative issues include:
• oversubscribed GP and dental practices,
• reduced school PAN at Langenhoe Primary,
• rising wastewater failures exacerbating tide-locked flood risk,
• congested roads frequently blocked during high tides.

CCC has not demonstrated a cumulative impact assessment for this allocation.
This failure renders PP49 not justified or effective under NPPF 27 & 35.

7. Deliverability and Viability Concerns (NPPF 36c & 69)

Site PP49 requires:
• drainage upgrades,
• foul water infrastructure improvements,
• road safety interventions,
• biodiversity mitigation,
• transport enhancements.

Since February 2024, reaffirmed in Policy EN2, Biodiversity Net Gain (BNG) of 10% is a mandatory statutory requirement for new developments. WHPC challenge CCC to demonstrate how they can achieve 10% BNG on-site given the density of 25 homes. Often, developers cannot fit 25 homes and the required 10% habitat improvement on small sites without buying off-site credits. Off-site credits are not sustainable.
No evidence has been provided that any of these measures are viable, funded, or deliverable within the plan period (NPPF 69).

The site's retention fails the deliverability (NPPF 69) and effectiveness (NPPF 36c) tests because the Council has not demonstrated that the mandatory mitigation requirements are viable or funded.

• Viability Challenge: The "Colchester Whole Plan Viability Appendices" (October 2025) and associated evidence must be publicly used to demonstrate that the site can financially support both the costly infrastructure mitigation (drainage, highway safety) and the required 30% Affordable Housing target (Policy H1). In the absence of this proof, the WHPC asserts that the costs of mitigation render the site unviable for allocation.

• Uncertainty of Delivery: The allocation is being progressed without confirmed funding or a timeline for the essential Anglian Water upgrades and the delivery of the required 10% Biodiversity Net Gain (BNG), meaning the site is not capable of being "met over the plan period" (NPPF 69).


8. Infrastructure and Mitigation Requirements (If Allocation Were to Proceed)
Without prejudice to its position that PP49 should be removed, WHPC sets out required mitigation if CCC chooses to retain the allocation.

• A maximum of 25 houses.
Reason - any more would adversely affect the nature of the village.
• 2 and 3 bedroom houses to be included in the development.
Reason - to provide affordable housing for both younger and older people wishing to remain in or return to the village.
• Affordable Housing Requirement – in line with Colchester Local Plan Policy H2, at least 30 % of new dwellings on this site should be provided as affordable housing, consistent with the rural village threshold of more than 5 dwellings.
In the event the site is retained, the resulting 30% Affordable Housing units must be delivered through a Section 106 Agreement that prioritises applicants with a verifiable "local connection" to the Parish of Peldon. This connection must be defined as:
o Applicants currently residing in Peldon for a minimum of five years.
o Applicants who have previously resided in Peldon for a minimum of ten consecutive years.
o Applicants whose immediate family (parents, siblings, adult children) currently reside in Peldon and have done so for a minimum of five years.

Any reduction below the 30% must be justified by viability evidence.
• Off street parking for at least two cars per property.
Reason - WHPC is aware of local developments with insufficient off-road parking causing on street parking which impedes access by emergency vehicles.
• The roof line of the houses should not block views from the house on Church Road.
Reason - WHPC recognises there is no legal right to a view, removing the view that exists would be a significant loss of amenity for the residents of those properties.
• The houses should not overlook the houses on either Lower Road or Church Road
Reason - Loss of privacy
• Houses should be in keeping with the character of the area in terms of both size and height.
• The houses should not overlook the playing field and children’s playground in Moss Hay
Reason - Private sightlines into a recreation area used by children and young people should be avoided.
• No street lighting or intrusive external lighting attached to the properties
Reason - To avoid light pollution. Peldon does not have any streetlights and it would be out of keep with the character of the village to have any. NPPF 198 states c) limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation.
Peldon still has reasonably dark skies, measuring 4 on the Bortle scale. The centre of Colchester is Bortle 6. The difference in what you can see in the night sky is significant. Additionally, the detrimental impact on nature of the overall increase in light pollution is well documented.
• Houses should have the necessary infrastructure for highspeed broadband.
Reason – the only full fibre internet in the village is provided by County Broadband (recently merged with TrueSpeed) via infrastructure they installed. They have sole use of it. The only other option is the copper wire connection maintained by Openreach and the speed of connection is slow. People moving into the houses should not have to wait for months for a proper connection to be installed.
• The design of the roofs of the houses should be such to maximise the opportunity to generate solar energy.
Reason – Solar Panels and Heat Source Pumps should be installed for all the houses. Both are greener sources of power and heating. Having solar panels helps to offset the cost of running a heat source pump
• Improved public transport running more reliably and frequently direct to the city centre, train station and hospital.
Reason – To reduce car journey and make the village more connected.
• Ensure access to the site is safe and adequate for the users.
• Improve road safety and congestion factors on St Ives Road, in particular for the safety of users including pedestrians.
• Green space allocation within the site.
• Keep and maintain mature hedges and trees
Reason - to preserve the wildlife habitat as far as possible.
• Require Anglian Water to upgrade surface and foul water services.
 

9. Profile of Peldon

Peldon is a small rural village of approx. 220 dwellings, mostly in ribbon formation around the Peldon Triangle, with:
• no local services (shops, schools, medical facilities),
• no pavements for most of the village,
• no street lighting (a valued characteristic),
• limited bus service, often unreliable,
• limited broadband options, with only one full-fibre provider (County Broadband/TrueSpeed).
The community includes:
• a significant older population,
• families who rely on car travel for all work, school and daily needs,
• residents who grew up here but cannot afford to live locally due to lack of small, suitable housing.
This demographic evidence underscores Peldon’s classification as a “Small Settlement” suitable only for small-scale and locally justified development.

10. Summary and Conclusion

For all the reasons detailed above, Site PP49 – Land at St Ives Road, Peldon is unsound and legally non-compliant when assessed against the NPPF tests of soundness (NPPF 36):

1. Not Justified: No demonstrable, locally defined need for 25 open-market dwellings (Housing Needs Survey).
2. Not Effective/Deliverable: Severe, unmitigated constraints regarding highway safety (NPPF 116) , infrastructure (NPPF 7 & 20b), and viability.
3. Not Consistent with National Policy: Breach of the Habitats Regulations (HRA) regarding the Abberton Reservoir SPA/Ramsar site and conflict with the settlement hierarchy (Policy ST1).
The scale, location, and nature of development proposed are incompatible with Peldon’s setting, infrastructure, services, accessibility and character, and would result in an unsustainable pattern of growth.

WHPC therefore formally requests that Site PP49 be removed from the Preferred Options and not taken forward into the Regulation 19 Local Plan. Should the site be retained at Regulation 19, WHPC reserves the right to appear at the Examination in Public.
 

11. Appendices

Appendix A – Detailed Objections

This appendix provides detailed evidence supporting WHPC’s objection to large-scale development in Peldon. Unless otherwise stated, distances refer to road distances from a central point in the village. Due to the presence of Abberton Reservoir, road distances give a more realistic representation of daily life in Peldon than straight-line measurements.

The objections below apply to large-scale development in Peldon generally, including Site PP49 (Land at St Ives Road).

A1. Public Transport
A1.1 Limited and unreliable bus services
Peldon is served by an extremely limited public transport network. The reality of provision is poorly reflected in published timetables.
• The timetables refer to “The Peldon Rose” as a bus stop; however, this stop lies at least one mile from the main settlement, along a busy, unlit road with no pavements.
• The only bus service passing through the main settlement is Route 63, which operates infrequently.
• The service is not reliable: during high tides, drivers often terminate early in Abberton, leaving residents stranded. At other times, buses fail to appear either in the village or at Colchester stops, despite repeated complaints by residents and representations by WHPC.
• No improvement has occurred despite long-standing concerns.
Public transport is crucial for older residents, many of whom do not drive, yet the current service cannot be described as adequate.
A1.2 Inability to access education for 16–18 year-olds
There is no bus service enabling students aged 16+ to reach Colchester education providers (Sixth Form College, Colchester Institute, etc.) for 09:00 starts.
Although young people must remain in education or training until age 18, local authorities are not required to provide transport beyond age 16, creating major practical burdens for families.
Where children attend grammar schools, independent schools, or alternative secondary schools, the situation is even more difficult.
A1.3 Unsuitability for sustainable travel
Peldon:
• is not within reasonable proximity to a railway station,
• has no cycle routes connecting to employment centres,
• is therefore wholly reliant on car-based transport.
Consequently, Peldon is not suited to large-scale new housing under the sustainable transport requirements of the NPPF.

A2. Medical Services
A2.1 Lack of local provision
Peldon has no GP surgery and no dental practice.
A2.2 Nearest practices are oversubscribed or inaccessible
• The West Mersea GP practice (3.3 miles away) is oversubscribed with closed lists, and capacity has not increased alongside significant housing growth on Mersea Island. Many residents report being unable to register, and it is occasionally tide-locked from Peldon.
• The West Mersea dental practice is also closed to new NHS patients.
• Travel by bus is extremely limited; high tides frequently sever access.
The next-nearest medical practices offer no better prospects:
• Winstree Medical Practice, Layer-de-la-Haye:
o Base site: 4.9 miles away
o Main branch: 8 miles away
o No public transport to either location.
• Tollesbury Practice, 6.6 miles away:
o No public transport available.
The NHS website confirms that Peldon’s central postcode falls only within these three catchment areas, all suffering capacity, access, or transport constraints.
Large-scale development in Peldon would significantly worsen the situation.

A3. Schools
A3.1 No primary school in Peldon
The nearest primary school is Langenhoe Primary School, located in Abberton, 2.1 miles away.
• The school reduced its Planned Admissions Number (PAN) from 22 to 15 in September 2024.
• Significant new housebuilding in Abberton is already increasing demand on available school places.
• The Local Plan allocates a further 50 houses at Abberton, which will intensify pressure.
Even before considering the PP49 allocation, local families in Peldon report concern about access to school places.
A3.2 Secondary school access
Peldon has no secondary school. The village lies within the catchment for:
• The Thomas Lord Audley School (Colchester)
• Thurstable School (Tiptree)
School transport is provided only until age 16.
Families where children attend grammar schools, out-of-catchment schools, or fee-paying schools receive no transport, placing a heavy reliance on car travel.
As noted earlier, without viable public transport for 16+ students, a parent or guardian must be available for all school–college travel after GCSE age.

A4. Shops and Local Amenities
Peldon has no shop.
Nearby options include:
• Langenhoe Community Shop (2.2 miles) – limited stock, not a weekly shopping option.
• Bonners Barn Farm Shop (1.4 miles) – also unsuitable for full weekly shopping.
Buses are infrequent, poorly reliable, and walking is unsafe due to:
• lack of pavements,
• unlit roads,
• fast-moving traffic.
Everyday essentials require car travel.

A5. Roads and Highway Safety
A5.1 St Ives Road is already inadequate
St Ives Road is a primary route through Peldon for residents of:
• Lower Road,
• part of Mersea Road,
• surrounding lanes feeding into the village.
Existing issues include:
• Narrow carriageway, including sections too narrow for two cars to pass.
• The junction with Church Road has poor visibility, requiring drivers to pull into the carriageway before they can see approaching traffic.
• Heavy use by buses, farm vehicles, delivery vans, and commuters.
• Increased traffic during high tides, when congestion around the Peldon Rose forces more vehicles via St Ives Road.
These constraints are not apparent from maps but are part of daily lived experience for residents.
A5.2 Expected traffic generation
Most Peldon households have two cars. Households with older children often have more.
A 25-house development would therefore likely generate:
• More than50 cars,
• Increased peak-time movements,
• Pressure on an already constrained road network.
This would materially worsen safety on St Ives Road and surrounding lanes.
The residual cumulative impacts on the road network would be severe.
No recent traffic survey has been conducted to validate the capacity of St Ives Road.

A6. Water Supply and Wastewater
Residents express serious concerns about:
• Anglian Water’s ability to maintain fresh water supply given wider regional growth,
• the capacity of the foul water system,
• surface water drainage issues.

Local evidence includes:
• Regular attendance by Anglian Water at the Mersea Road pumping station during heavy rainfall, indicating capacity stress.
• Surface water flow paths across PP49 (confirmed by Environment Agency mapping).
• Existing minor flooding events in the village.
Any development would require significant upgrades, none of which have been demonstrated as viable or deliverable.

A7. Summary of Appendix A
Peldon’s infrastructure, transport, services, road network, and environmental constraints are fundamentally incompatible with large-scale housing growth. The reality on the ground is one of limited services, insufficient capacity and poor connectivity — conditions that cannot support a 25-house development without substantial and unjustified intervention.

Appendix B – Resident Opinion Summary

WHPC undertook extensive consultation with local residents and this response reflects the opinions and evidence gathered from the consultation process.
Summary of Opinions by Site.
As well as gathering opinions on the St Ives site, WHPC collated residents’ views on the other sites which had made it to Stage 2 of the Local Plan process.

10177 – Gt Wigborough
This has been discounted by CCC as being “detached from the settlement and facilities when compared to other sites”. The site is close to housing in the School Lane area. Great Wigborough does not have any significant amenities and facilities. This site may offer suitable vehicle access on to a suitably wide road.

10621 Land at St Ives Road
Wide opposition was expressed to the use of this site. Infrastructure, road usage and road safety, the creation of an estate which would not be in keeping with the village, lack of any amenities and infrastructure concerns were all cited as reasons for opposition. In addition, the loss of a natural habitat was also put forward in opposition. There are established hedges and mature trees bounding the site which should be preserved to protect the habit for the wildlife.

A small number of respondents considered St Ives Road could be used, if concerns on traffic congestion, road safety, public transport and infrastructure and amenity, affordable housing and biodiversity are addressed. There was considerable concern that if development were permitted on this site, it would lead to further development incursions into the Peldon Triangle in the future.

10179 Sawdon - Kemps Farm.
Some respondents expressed the view that this could be a suitable site. The stated reason to discount is, “the site is considered detached from the settlement and facilities, when compared against alternatives. A large proportion of the site is also located in Flood Zones 2 and 3.” The site suffers from the same lack of infrastructure as the St Ives site. The flood risk can be managed by suitable drainage systems. There are many examples of developments on flood zones in Colchester for example, Meander Mews on Cowdray Avenue.

10181 Peldon Hall Farm.
Some respondents supported this site for a small number of houses which may blend in with the houses previously built on Church Road and Maltings Road.

10228 Land adjacent to Lower Road.
No respondents supported this site.

10663 Land off Newpots Lane.
Concerns were expressed developing here might lend approval to the adjacent field south of Mersea Road, which would be inappropriate.

10673 Land South of Mersea Road.
Discounted by CCC saying, “Development of this scale would harm the character of the village”. The respondents agreed that a development of the scale of the proposed site would adversely affect the character of the village. Additionally, it was felt by many that allowing a small development on this site could be the start of the whole site being built on. There was very strong opposition to this.

Several respondents expressed the view that any additional housing could be spread across several small sites across the villages (Peldon and Wigborough) rather than one estate of 25 houses.

Appendix C – Photographic Evidence
o Photo 1: View looking up St Ives Road
o Photo 2: View showing limited visibility at Church Road junction

Appendix D – Housing Need Survey
Winstred Hundred HNS Report March 2024.pdf