Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

The Vision needs to be more explicit in recognising the challenge created by the new housing numbers the City has to accommodate, particularly in those areas that have not seen this scale of development in the last 50 years. There needs to be a clear commitment embedded in the Vision to mitigate the impact of major housing growth and for the Plan to demonstrate evidence of how this mitigation will be delivered. The Vision and Plan as drafted are too vague for the scale of the task.

The successful implementation of this policy will be an important component in the mitigation referred to in the Comments made on the Vision. the Parish Council supports the policy but looks to see it strengthened to make specific reference to the Roman River Valley west of Colchester, now recognised in the Essex Landscape Renewal Strategy, but which is not adequately recognised in the Landscape Character Assessment 2024 non which the Preferred Options appears to rely.

There is no rationale or evidence to support the reference to 'appropriate level of growth', particularly for the Medium and Smaller Settlements. There is no evidence to demonstrate capacity in these settlements to accommodate further growth. Allocations have been made simply on the basis of responses to the Call for Sites. This is not planning. The appropriate level of growth in each settlement should have been assessed and consulted on and then tested through the Call for Sites to prove deliverability, not the other way round.

Given the scale of growth proposed in the Medium and Smaller settlements, the final paragraph of this policy provides inadequate protection to the villages and rural areas from future speculative, piecemeal development and the policy should be strengthened to clarify that permission outside defined settlement boundaries will only be granted exceptionally and the presumption is that such development would be unsustainable.

The Parish Council objects to this policy on the grounds there is no explanation, justification or rationale for the way the number of new homes have been allocated to the Medium and Smaller Settlements. The only criterion appears to be that the sites were put forward in the Call for Sites by landowner or promoter. No assessment was made of the capacity of any settlement to inform decisions.

The text at para.3.51 is incorrect and attributes the wrong parishes to PP17 and 18

Given the scale of the challenges highlighted in the updated IADP 2025, the Jacobs Further Transport study and the Viability Assessment this policy is not fit for purpose and as currently drafted is too weak to deliver the funding needed to support the level of development proposed over the next 15 years. The key elements of the IADP need to embedded in the Plan with clear links between development sites and what contributions are required for off site improvements to support the growth. Serious and urgent consideration should be given to the scope for CIL to be a better way of securing the funding for the investment needed to secure the modal shift that the conclusions in the Jacobs Report rely on. The policy as drafted is vague and non specific. The ambition for the modal shift needs to be front and centre. There is currently no policy statement on transport which is a major omission. The City Council's record on s106 funding, despite record levels of housebuilding over the last ten years, is poor and it is not clear by what means this can be transformed to mitigate the impact of future development. Policy ST7 as drafted will not achieve this. The Viability Assessment claims the larger sites can contribute £30,000 per home. This should be the starting point and the requirements clearly stated and embedded in policy.

The minimum 10% POS on all sites is supported there should be specific reference to the Strategic Sites and Growth Areas that require more than 10% and this should be specified wherever possible, ie PP17 and PP18 for the avoidance of doubt.

The Parish Council support the reference to the Roman River Valley, and in particular the section west of Colchester, as part of the Essex Local Nature Recovery Strategy. The notation on the Proposals Map should be widened to encompass the wider valley slopes within Aldham Parish to ensure they are protected from development. This would take in an area from the railway line on the northern boundary to the 40m contour line to the south to inform masterplanning on PP18

The aims and ambition are supported but the policy as drafted is weak and does not set out a clear vision or contain sufficient detail to deliver the transport and other infrastructure necessary to mitigate the impact of proposed development over the next 15 years. There should be a clear commitment to the modal shift that is recommended in the Jacobs Report 2025 as well as key elements of the IADP, with measurable targets for what needs to be delivered by whom and when and any phasing required to ensure infrastructure keeps pace with development. The scale of development is not dissimilar to that proposed for the Garden Community at West Tey but over a shorter time scale. This demonstrates the scale of the challenge and the potential risks of the Plan being unsound if strong enough policies are not in place. Representations have been made elsewhere on the need for an urgent review as to whether the Council can satisfy an Inspector at Reg.19 that the Plan will be deliverable relying solely on s106 agreements, or whether CIL is a more appropriate mechanism to deliver the infrastructure and mitigation required. In either case a clearer set of requirements drawn from the evidence base need to be related to individual sites, and especially the larger strategic sites, to ensure there is no ambiguity when it comes to negotiations on individual sites

PC5 should include policy wording to discourage the use of Class Q, conversion of farm buildings, as a means of securing inappropriate development in the countryside on the basis the Class Q PD creates a precedent for replacing with new development contrary to policies protecting the countryside.