Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

1. INTRODUCTION
West Mersea Town Council strongly objects to the proposal in Draft Local Plan to put 300 dwellings at West Mersea because the Draft Local Plan does not recognise that Mersea is an Island with restricted access due to it’s single tidal road with poor public transport. Also the limited room for 1
expansion for future generations (NPPF), with the whole Island lying within the Coastal Protection Belt and some seven other conservation areas.
Mersea Island, Water Quality, and Biodiversity Constraints
Mersea Island is an ecologically sensitive and legally protected tidal island at the confluence of the Blackwater and Colne estuaries, connected to the mainland only by the tidal causeway, The Strood. It supports internationally important estuarine habitats, including saltmarshes, mudflats, and shingle beaches, and is covered by multiple environmental designations, including a Marine Conservation Zone (MCZ). The island is also renowned for its native oyster fishery, a key part of the local economy, tourism, and cultural heritage.
A recent river survey undertaken by Anglian Water and commissioned by the Environment Agency highlighted the high frequency and volume of discharges from the West Mersea Water Recycling Centre (WRC). The survey identified a long-term deterioration in water quality. Despite upgrades, 2025 bathing waters recorded the highest bacterial spike on record, with human sewage identified as the source, demonstrating ongoing risks to sensitive marine habitats.
Native oysters and other Priority/irreplaceable habitats are recognised as highly threatened globally. Restoration efforts through the Essex Native Oyster Restoration Initiative are underway. The Food Standards Agency has confirmed that further housing on Mersea Island will have a measurable effect on water quality and protected oyster beds, increasing nutrient and bacterial loading. Natural England (Feb 2023) has requested evidence that additional development will not harm designated marine sites. The Plan, however, does not reference the MCZ, nor does it assess cumulative wastewater impacts from existing or proposed development.
The original Dawes Lane and Brierley allocations were approved without any consideration of the MCZ, despite functional links to sensitive habitats, and the Plan now proposes an additional 300 dwellings at Dawes Lane, raising the total development pressure on West Mersea to approximately 600 homes. The Sustainability Appraisal fails to assess these allocations in combination, contrary to SEA and Habitats Regulations, and ignores potential significant harm to the MCZ, SPA, Ramsar site, SAC, and Priority/irreplaceable habitats.
Critical other constraints and infrastructure issues are also omitted: transport impacts have not been adequately considered, and healthcare provision is insufficient, with nearly one full-time doctor per 2,800 patients and closed patient lists. While building extensions for medical staff are proposed, there is no evidence of increasing the number of doctors to meet demand.
Accordingly, the Plan raises serious concerns regarding compliance with Policies EN1, EN3, ST7, NZ3, CS5, CS6, LC1/LC3, and site-specific allocations including PP23 (West Mersea), particularly in relation to cumulative environmental impacts, MCZ protection, and potential significant harm to Priority and irreplaceable habitats.
Crossing onto Mersea Island just as the tide meets in the middle of the roadway B1025
Photo by Chrissie Westgate
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A big Spring Tide at the bottom of The Lane - Coast Road West Mersea
A moderately High Tide situation at the Strood
Red area indicates areas flooded to the 5m Ordnance Datum Level this would be equivalent to about 7.2 m surge high tide which overtops the seawalls, Lidar maps later showing the slump of seawalls
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Themes and Objectives
Create communities which reduce the need to travel, particularly by car for most of their daily needs. See also NPPF Para. 109 & 110 Promoting sustainable transport.
Comment:
Mersea Island can hardly be proposed as an area meeting these objectives with all the issues outlined and concerns due to access route onto the Island.
One of Mersea Island Red Squirrels photo Chrissie Westgate

ST1: Health and Wellbeing
Comment:
Policy ST1(f) requires that new development provides access for all to health facilities and services. However, the health assessment provides no forecast data for the West Mersea Surgery. Current medical provision is insufficient, with the doctor-to-patient ratio at approximately 1 full-time doctor per 2,800 patients (North East Essex figure is 2008), significantly above the national standard of 1:1,800, and patient lists are closed. Previously reported weighted patient numbers were 8,183 (102 East Road, 3 August 2020) and 8,238 (Dawes Lane, 6 March 2020, Carr-Hill formula). While the Plan indicates potential extensions to existing medical facilities, there is no commitment to increasing the number of doctors to meet patient demand. Access to off-island medical centres is also constrained by the tidal causeway and limited public transport, creating practical barriers to timely healthcare. Without evidence of increased capacity or mitigation, ST1(f) cannot be demonstrated, and the Plan fails to ensure adequate health provision for new and existing residents.

Policy ST2 commits to protecting and enhancing Colchester’s natural environment, including rivers, estuaries, and coastal areas, and ensuring sustainable management of water resources. On Mersea Island:
i) Cumulative housing development (existing, under construction, and proposed, approximately 600 homes) has not been fully assessed for its impact on water quality, nutrient loading, or sensitive habitats.
ii)West Mersea WRC discharges have already caused record bacterial spikes in bathing waters, confirmed by Environment Agency / Anglian Water surveys, demonstrating a link between wastewater and declining water quality.
iii) Natural England (Feb 2025) advises:
“We are keen to ensure that the Local Plan is able to evidence adequate sewage treatment infrastructure / Water Recycling Centre (WRC) capacity to serve new development without increasing the nutrient and pollutant load of WRC final effluent discharges and adverse impact to sensitive designated sites including Essex Estuaries Special Area of Conservation (SAC) and Blackwater, Crouch, Roach and Colne Estuaries Marine Conservation Zone (MCZ).”
iv)The 2021 Sanitary Survey (Carcinus Ltd / FSA) warns:
“Housing developments increase bacterial loading…[which] can negatively affect shellfish, including oysters, and impede the recovery of Marine Conservation Zone features.”
v)The Local Plan does not reference the MCZ nor provide evidence of sufficient WRC capacity. Failure to assess cumulative impacts from all existing and proposed housing risks breaching ST2 objectives, as estuarine habitats, intertidal areas, and native oyster beds are highly sensitive and protected.
Conclusion:
Without robust assessment and mitigation of wastewater impacts, ST2 cannot be demonstrated for Mersea Island, and the Plan fails to protect water quality, estuarine habitats, and the coastal environment. The Plan should reinstate a Mersea-specific policy, aligned with the WMNP, to ensure ST2 objectives are achieved.

Large settlements
Whilst West Mersea is a larger settlement outside Colchester it is fairly remote with major facilitates being some 13 Km away. Also the Station, Hospital and larger recreation facilities are on the North side of Colchester which entails negotiating the traffic pinch points to these facilities. Again public transport is difficult with the tidal Strood and change of buses at a chaotic bus station in Colchester.

Colchester infrastructure Audit and Delivery plan - Electricity
Table 5-1 Primary Substation Peldon Primary 11kV
Current Max Demand (MW) 15
Demand Headroom Availability36.7%
Max Capacity (MW) 23.7
Spare Capacity (MW) 8.7
Est increase for emerging development 4.8
Est 2041 Peak Demand (MW) 19.8
Demand Headroom Availability Green (Over 5%)
However there seems to be little or no consideration for the 300 proposed dwellings at West Mersea not being allowed to fit Gas Boilers and therefore presumably requiring night store/electric heating or Heat pumps.
Also no allowance seems to have been indicated for the 64.4%* of the dwellings at West Mersea having Gas Boilers and 14.4 %* having Oil Fired Boilers. All to be converted before the end of 2050, some 9 years after the plan period 2041.
No allowance for electric car charging and the general increase in usage of electrical devices.
It is noted that there is now a coffer damn around the main electric sub station supplying Mersea Island and we hope this will work in practice.
* WMPP survey of households 2020
ST7 requires that necessary infrastructure is in place to support development and mitigate its impacts. Without proper assessment and provision for additional sewerage arising from new development, key infrastructure requirements are not secured. This undermines ST7, as well as the effectiveness of Policies LC1 (Landscape), EN3 (Biodiversity and Geodiversity) and ST2 (Environment, Green Network and Waterways), because environmental impacts on waterways, habitats, and landscapes cannot be properly mitigated. Policy EN3 (Biodiversity and Net Gain) requires development to avoid harm to habitats and species and deliver measurable net gains for biodiversity. Additional sewerage and wastewater from new development can degrade water quality in rivers, estuaries and coastal areas, harming habitats and species and making net gain unachievable. Where sewerage impacts are not properly assessed or mitigated, compliance with EN3 cannot be demonstrated, and the objectives of ST2 (Environment, Green Network and Waterways) and ST3 (Infrastructure Delivery and Impact Mitigation) are also undermined.
WRC Capacity & Wastewater:
i) The IADP does not demonstrate that the Water Recycling Centre (WRC) can accommodate cumulative housing allocations (~600 dwellings, including existing Local Plan and West Mersea Neighbourhood Plan dwellings).
ii)The only operational change (increased storm flow) does not provide additional treatment capacity for new development.
Environmental Policies at Risk:
Without adequate wastewater mitigation, development risks breaching:
LC1 – Landscape and Coast
LC3 – Coastal Protection Belt
EN3 – Biodiversity and Net Gain
ST2 – Environment, Green Network and Waterways
ST3 – Infrastructure Delivery and Impact Mitigation
NZ3 – Wastewater and Water Supply
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Marine Conservation (MCZ/SAC):
i)Features of the MCZ (native oyster beds, intertidal sediments) and the Essex Estuaries SAC are in unfavourable condition and under active recovery.
ii) Any additional nutrient, chemical, or bacterial load from the WRC will hinder recovery and compromise conservation objectives.
iii) The 2021 FSA Sanitary Survey confirms that housing developments increase bacterial loading, which negatively affects shellfish, including oysters.
Cumulative Impacts:
All existing and proposed housing allocations must be considered together in assessing WRC capacity and environmental impacts.
Required Actions for Sound Plan:
1. Provide evidence of cumulative WRC capacity for all housing allocations.
2. Include timing and delivery of wastewater infrastructure upgrades before occupation.
3. Assess and mitigate impacts on MCZ, SAC, and coastal/estuarine landscapes.
4. Reinstate a Mersea Island-specific policy to protect sensitive coastal and estuarine areas.
Conclusion:
Without these measures, the IADP is incomplete, and the Local Plan cannot be considered sound.

Comment: See LC1 BELOW
The development proposed under policy PP23: Land East Dawes Lane falls within the Coastal Protection Belt and is productive farm land which seeks to protect and enhance landscape character. Additional sewerage and wastewater from new development can cause indirect and cumulative harm through degraded watercourses, estuaries, and coastal waters, impacting habitats, landscape character, and visual amenity.
The Local Plan cannot be considered sound unless it explicitly assesses and mitigates additional sewerage and wastewater impacts on these sensitive landscapes, habitats, and designations, ensuring compliance with LC1, EN3, ST2, and ST3.

However, alternative SANGs should not be allocated on Mersea Island unless they are directly linked to development on Mersea itself. Using off-island mitigation for Mersea development
would undermine the local environmental integrity, connectivity, and ecological resilience and would conflict with the intent of Policy EN2 to secure direct, locally appropriate biodiversity net gain.

Policy EN3 requires that new development protects and enhances biodiversity and geodiversity, delivering net gains wherever possible. On Mersea Island, the sensitive estuarine habitats, saltmarshes, mudflats, and intertidal areas are already under pressure from cumulative impacts, including wastewater discharges from the West Mersea WRC.
Additional housing, without full assessment and mitigation, risks further nutrient and bacterial loading, harming native oyster beds, wading birds, and protected habitats (MCZ, SAC, SSSI). These impacts undermine the ability to achieve net gain and may hinder ongoing restoration efforts such as the Essex Native Oyster Restoration Initiative (ENORI).
Without robust cumulative assessment and mitigation, EN3 cannot be demonstrated for proposed development on Mersea Island, and the Plan fails to secure the biodiversity and geodiversity objectives it sets out.

Red squirrels are present on the Island and care must be taken to protect their habitats.
Oyster Habitats
Additional housing, without full assessment and mitigation, risks further nutrient and bacterial loading, harming native oyster beds, wading birds, and protected habitats (MCZ, SAC, SSSI). These impacts undermine the ability to achieve net gain and may hinder ongoing restoration efforts such as the Essex Native Oyster Restoration Initiative (ENORI).