Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

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Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy ST5: Colchester's Housing Need

Representation ID: 13858

Received: 14/01/2026

Respondent: Bloor Homes (Eastern) - Tiptree

Agent: Pegasus Group

Representation Summary:

The Council will need to make additional residential site allocations to meet its minimum housing requirement. The Land north of Maldon Road, Tiptree is suitable, achievable and available for development. The findings of the previous Appeal at the site can be addressed through reducing capacity and promoting a sensitive design solution. The site should be allocated in the Local Plan.

Full text:

Paragraph 12.22 - Tiptree

As set out in Bloor Homes’ representations to draft Policy ST5 and ST5.2 there is a clear need for additional site allocations to be made to ensure that the new Local Plan is capable of meeting the minimum Standard Method housing need. At present, the strategic approach to building a robust supply is not justified and is inflexible. The proposed supply would not be capable of responding to changes in the housing market during the Plan period. Furthermore, the supply of proposed site allocations contains several sites where capacity (no. of dwellings) has been overestimated.

Moving forward towards the Pre-Submission stage it appears inevitable that, alongside reviewing the above matters, the Council will need to make additional site allocations for residential development. In making new site allocations the Council will need to follow their chosen Spatial Strategy to deliver growth and have due regard for the proposed Settlement Hierarchy which ranks existing settlements based on their sustainability credentials. As set out in Bloor Homes’ representations to draft Policy ST3, Tiptree is a sustainable settlement capable of accommodating housing growth.

Bloor Homes continue to promote the land north of Maldon Road, Tiptree for allocation. The land is identified as a potential Neighbourhood Plan growth area in the adopted Local Plan. However, currently the site is not identified as a draft site allocation in the Preferred Option Local Plan (POLP) or in the Tiptree Neighbourhood Plan. Over the course of 2024/2025 Bloor Homes have met with Tiptree Parish Council and it is our understanding that the Parish Council may wish to review their Neighbourhood Plan in the future. It is assumed that in undertaking a Neighbourhood Plan review there would be a local ambition to take a lead role in assessing and identifying potential site allocations to meet local housing needs. However, currently the POLP leads on making site allocations across Colchester, thus potentially bypassing the Neighbourhood Planning process. Moving forward, clarity is required as to the role of Neighbourhood Planning in delivering local housing needs and identifying site allocations. This is particularly important in areas where there is already a Made Neighbourhood Plan. If Neighbourhood Plans are to have a proactive and influential role in meeting local housing needs, a new policy mechanism and potentially a settlement housing requirement is needed in the Local Plan.

Over the course of 2025 the land has been subject to an outline planning application (LPA Reference: 250435) for up to 165 homes and a community car park. In September 2025, the planning application was refused by the Council for four reasons. A planning appeal was subsequently submitted on the 1st of December 2025.

The first reason for refusal relates to matters of principle, which would be resolved if the site was allocated in the adopted Local Plan or identified by the Parish Council through a Neighbourhood Plan Review. Reason for refusal No.3 and No.4 can be resolved by Bloor Homes entering into a S106 agreement with the Council as part of a planning permission.

The second reason for refusal relates to a perceived impact on the local landscape and wider character of the area and is a matter which to some extent is subjective. Bloor Homes believe that the Framework Masterplan and supporting evidence in the planning application and Planning Appeal clearly demonstrates that a sensitively designed development can come forward at the site which maintains a gap between Tiptree and Tiptree Heath. Indeed, the previously dismissed Planning Appeal (Ref: APP/A1530/W/20/3248038) at the site relating to a proposal for 255 dwellings confirms that “There seems no reason why some development could not take place within that Broad Area whilst still maintaining a recognisable gap between settlements”. Bloor Homes firmly believe that the proposal for up to 165 dwellings addresses the matter of landscape and character robustly.

Regardless of the ongoing Planning Appeal process, the site and the proposals should be subject to an updated Strategic Land Availability Assessment (SLAA) appraisal and Sustainability Appraisal. The land has a current SLAA Reference of ID10486. The planning application process has demonstrated that the proposed development is acceptable in respect of a range of technical matters. Matters found to be acceptable (subject to the inclusion of planning conditions and planning obligations) through the planning application process were as follows: highways access, highways impact, flood risk and drainage, heritage, archaeology, trees, on-site ecology, biodiversity net gain, agricultural land classification, ground conditions, minerals safeguarding, noise, air quality and health. This should be reflected in the SLAA.

The Framework Masterplan and Vision Document submitted in support of these representations replicate the proposal which has been put forward via the 2025 planning application and the more recent Planning Appeal submission. The Framework Masterplan delivers:

• A developable area of 4.64ha, with the density of the development being 35 dwellings per hectare (4.64ha of residential area/165 dwellings). The density of the development will vary across the site between development parcels to deliver a mix of dwelling sizes and types (to meet local needs) and to respect the more sensitive areas of the site in environmental terms. The proposal provides a policy compliant 30% affordable housing which equates to up to 50 dwellings.

• Single storey bungalows are proposed adjacent to existing bungalows on the western boundary with Peakes Close. This approach will protect the amenity of residents at Peakes Close.

• 4.42ha of public open space comprising amenity space, natural green space, landscaping and play provision. An additional 0.33ha of attenuation space is also provided. Within the open space provision is a series of walking routes which connect to other existing routes in the local area. The proposed on-site routes will be suitable for dog walkers, with dog bins provided.

• The primary access to the development is at the south western end of the site off Maldon Road. The access proposals include the provision of a signalised puffin crossing on Maldon Road. The introduction of this controlled crossing facility responds directly to feedback received from representatives at Tiptree Heath Primary School. The existing track access to the east of No.96 Maldon Road is to be retained and upgraded as this route will be the most convenient route to Tiptree town centre for the majority of residents of the scheme.

• The proposals include a community car park to address existing pressures at Tiptree Heath Primary School. The car park has an indicative capacity of 30 spaces sufficient to accommodate the parking needs of the school at peak drop off and pick up times.

The land being promoted by Bloor is suitable, achievable and available for development. The site can help the Council deliver a robust housing supply to meet its Standard Method need. The site should be subject to a new SLAA appraisal and Sustainability Appraisal. These appraisals should then be published as part of or prior to the Pre-Submission Local Plan consultation.

There is a robust and clear case for the site to be allocated for residential development.

Support

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy ST3: Spatial Strategy

Representation ID: 13867

Received: 14/01/2026

Respondent: Bloor Homes (Eastern) - Tiptree

Agent: Pegasus Group

Representation Summary:

Tiptree’s designation as a ‘Larger Settlement’ is supported. Tiptree should be a focus for proportionate and sustainable levels of housing growth owing to its positive sustainability credentials. The sustainability of delivering 910 dwellings at Langham, should be subject to further review.

Full text:

The proposed Spatial Strategy seeks to deliver housing growth to the most sustainable and accessible locations in Colchester. This includes directing appropriate and proportionate levels of growth to Large, Medium and Small Settlements, in accordance with the Settlement Hierarchy.

The Council’s evidence underpinning the proposed Spatial Strategy and Settlement Hierarchy is set out in the Preferred Options Spatial Strategy Topic Paper and the Settlement Evidence Report (Stage 1 and Stage 2). The Settlement Hierarchy sets out at page 23 of the Preferred Options Local Plan (POLP) six tiers of settlements or locations. Tiptree falls within the ‘Larger Settlements’ tier, along with two other settlements. This is a change in classification from the adopted Local Plan, where Tiptree is grouped as one of 17 ‘Sustainable Settlements’. Thus, the Council have felt it necessary to promote Tiptree in sustainability credentials terms. Bloor Homes support Tiptree’s identification as a ‘Larger Village’. Owing to its size and service provision, the settlement is clearly capable of supporting sustainable levels of housing growth during the new planning period.

In light of its sustainability credentials and position in the Settlement Hierarchy, Tiptree is currently assigned to deliver approximately 645 dwellings across four sites during the plan period. The suitability of the proposed site allocations and the availability of alternative sites should be considered further by the Council in the lead up to the Pre-Submission consultation stage. Indeed, Bloor Homes are promoting Land to the north of Maldon Road for residential development of up to 165 dwellings.

It is noted that the ‘Medium Settlement’ of Langham is assigned to deliver 910 dwellings over the plan period. This is 480 dwellings more than any other ‘Medium Settlement’ and significantly higher than any of the ‘Larger Settlements’ identified in the Settlement Hierarchy. Whilst Bloor Homes acknowledge that to some extent the availability of land will inform the size of proposed site allocations, the current figure for Langham is disproportionately high in comparison to other sustainable settlements such as Tiptree (and a range of others). Further evidence is required to justify the proposed approach.

Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy ST5: Colchester's Housing Need

Representation ID: 13877

Received: 14/01/2026

Respondent: Bloor Homes (Eastern) - Tiptree

Agent: Pegasus Group

Representation Summary:

The deliverability of committed sites in the proposed housing supply needs to be evidenced. As proposed, and assuming all of the committed sites are deliverable, there is very limited headroom or flexibility in the Council’s housing supply to meet its minimum housing requirement. This matter is compounded by the reliance on windfall sites. Additional site allocations for housing are required to ensure the Plan is capable of meeting the minimum housing requirement.

Full text:

The Preferred Options Local Plan (POLP) seeks to address the Government's Standard Method housing need for Colchester in full. This equates to 1,300 dwellings per annum and 20,800 dwellings across the proposed plan period 2025-2041. The principle of the Council seeking to meet their Standard Method need is supported by Bloor Homes and accords with the requirements of the National Planning Policy Framework (NPPF). Indeed, the NPPF notes that meeting the Standard Method should be seen as a ‘minimum’ and this policy is carried forward in the draft NPPF published for consultation in December 2025. ‘Positive’ plan making to deliver new homes at suitable and available sites is a key priority for the Government and will continue to sit at the heart of national planning policy.

To meet the minimum requirement, at paragraph 3.37 of the POLP states that the Council has a committed supply of 6,117 homes made up of sites with planning permission and other sites with evidence to support early delivery. In this regard, it is contended by Bloor Homes that the Council currently has a 3.63-year housing land supply compared to the published position of 5.05 against the adopted Local Plan requirement. Thus, there is in excess of 1,000 dwellings in the Council’s supply which do not meet the NPPF’s definition of deliverable. In addition, paragraph 3.38 states that 1,700 dwellings of the Council’s supply during the Plan period will come from the Tendring Colchester Borders Garden Community. The deliverability of all these sites/dwellings needs to be evidenced by the Council at the Pre-Submission consultation stage.

In addition to the 7,817 dwellings identified above, paragraph 3.39 states that 2,200 dwellings (200 per annum) will come forwards as Windfall Sites. Accordingly, the Council contend that they have an initial supply of 10,017 dwellings over the Plan period. Table ST5.1 states that the other proposed site allocations in the POLP will deliver 11,089 new dwellings.

The POLP therefore stands to deliver 21,106 against a Standard Method need of 20,800 which results in a relatively limited buffer of +306 dwellings. This is the equivalent of a 1.4% buffer against the proposed housing requirement. This approach provides very limited flexibility in the Council’s overarching strategy to deliver the housing Colchester needs. Should the delivery of a small number of sites stall, there is limited flexibility and headroom for the Council to bring alternative sites forward at a faster pace. This approach could ultimately jeopardise housing delivery in Colchester. The importance of this point is made even more acute when considering that 10.5% of the proposed supply is accounted for by delivery at Windfall Sites at which delivery is not guaranteed or proactively planned for by the Council in terms of site identification.

Bloor Homes support and recommend the inclusion of a 10% buffer in proposed supply against the Standard Method minimum housing requirement. This should be achievable given the extent of sites promoted in sustainable locations via the Strategic Land Availability Assessment (SLAA) process and seemingly the strong record the Council has in terms of delivering Windfall sites.

Bloor Homes urge the Council to proactively plan to meet its minimum housing need in full. This can be achieved by making robust site allocations at deliverable sites and incorporating a sufficient buffer in the proposed supply of sites to allow flexibility over the plan period. The current approach, set out in the POLP, will inevitably lead to a shortfall in housing supply during the Plan period. It is apparent that additional site allocations for major residential development are required.

Finally, it is noted that a housing trajectory noting delivery rates and projected site commencements has not been provided as part of the POLP. At the Pre-Submission consultation a housing trajectory should be provided to allow further review of the proposed site allocations and their ability to deliver dwellings across the plan period.

Comment

Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Policy ST5: Colchester's Housing Need

Representation ID: 13892

Received: 14/01/2026

Respondent: Bloor Homes (Eastern) - Tiptree

Agent: Pegasus Group

Representation Summary:

The evidence base supporting the proposed allocation of sites for housing needs to demonstrate that a site can accommodate the number of dwellings proposed by the draft planning policy allocation. It is contended that the capacity of several proposed allocations is overestimated. The current approach will result in the under delivery of new homes and the Local Plan failing to meet the minimum housing requirement.

Full text:

Table ST5.2 Local Plan Housing Allocations

Bloor Homes notes the proposed site allocations for housing set out at Table ST5.2 of the Preferred Options Local Plan (POLP). The National Planning Policy Framework (2024) (NPPF) seeks Local Plans to identify a sufficient supply of and mix of housing sites. The new draft NPPF (2025) seeks Local Plans to identify a sufficient supply and mix of sites to meet or exceed the Plan’s housing requirements. The assessment of potentially suitable sites should be in accordance with published GOV.UK tool and guidance. The new NPPF specifically references the need for proposed allocations to be subject to an assessment of their capacity (Policy PM2c) which also takes into account infrastructure requirements.

Bloor Homes acknowledge that paragraphs 4.3-4.6 of the Site Allocations: Process Topic Paper (October 2025) provides some detail of how site allocation capacity is determined in general terms. Bloor Homes also notes that the ‘Summary of Site Evidence’ (October 2025) document provides high level reasoning and justification as to why a site allocation is proposed, however, the document does not provide an assessment of capacity or any detail regarding site capacity. Similarly, the Strategic Land Availability Assessment (SLAA) Site Assessment Report Stage 2 reviews the suitability, achievability and availability of proposed site allocations – but no assessment of site capacity.

In light of the above Bloor Homes has undertaken a high-level capacity review of all the proposed site allocations barring the Tendring Colchester Borders Garden Community. In undertaking this work, Bloor Homes has applied a 35 dwellings per hectare density and a developable area of 65% of the site area. Whilst it is acknowledged that this work is high-level it indicates that the site capacity at over 10 proposed draft allocation sites may have been overestimated. The implications of the potential inaccuracies in the Council’s site assessment process would result in the under delivery of approximately 1,100 new homes over the Plan period.

In making draft allocations the Council should have due regard for a site’s planning history. This includes carefully reviewing the detail of any previous planning decisions relating to a site made by the Council or Planning Inspectorate. It is acknowledged by Bloor Homes that in some cases previous reasons for refusal can be addressed through design amendments or by undertaking additional technical work. Despite this potential to overcome previous issues, Bloor Homes contend that at least one of the proposed allocations in the urban area of Colchester is not suitable based on the conclusions of an Appeal decision.

Bloor Homes’ representations to draft Policy ST5 already outline various concerns regarding the uncertainty and inflexibility of the Council’s proposed approach to making site allocations sufficient to meet the minimum housing requirements. The issue of sites potentially being identified with capacities greater than what is likely achievable would further jeopardise the Council’s and the Local Plan’s ability to deliver the new homes Colchester needs.

The above matters need to be investigated thoroughly by the Council as part of work leading towards the next Pre-Submission consultation stage. Based on the information provided to date it appears that additional site allocations for major residential development are required to meet the 21,106 dwelling supply figure put forward in the Plan.

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