Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

Bloor Homes are the promoter of part of the proposed site allocation at Land north of Coach Road, Great Horkesley, as identified on the Proposals Map associated with the Preferred Options Local Plan (POLP).

Bloor Homes are the promoter of the southern field of the two which are covered by the site allocation area. This land has a Strategic Land Availability Assessment (SLAA) reference of ID: 10691. Bloor Homes submitted an outline planning application for up to 150 dwellings and a community car park (Ref: 250545) in March 2025. Following a positive Officer recommendation, the planning application achieved a resolution to grant planning permission at the 27 November 2025 Planning Committee. The planning application process has determined that the site is a suitable location for residential development.

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, this includes the draft allocation Land north of Coach Road, Great Horkesley (Policy PP34).

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, Great Horkesley is a sustainable settlement capable of accommodating housing growth.

Given the evident need for the Council to identify additional land for housing development as part of the Pre-Submission Local Plan, Bloor Homes are promoting additional land to the south of Old House Road, Great Horkesley. The site covers 23.25ha and extends south from Old House Road. The site area includes the land which is subject to a resolution to grant planning permission (Reference: 250545) for 150 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site. Bloor Homes have instructed work to Masterplan this wider opportunity.

A Framework Masterplan covering the entirety of the land promoted by Bloor Homes (including the area covered by application 250545) has been submitted in support of these representations. The Framework Masterplan provides an indicative layout and demonstrates that a site capacity of 400 dwellings is achievable (based on 35 dwellings per hectare). This is the same density accepted by the Council in the determination and assessment of planning application 250545.

The Framework Masterplan delivers the following:

• 400 dwellings across a developable area of 11.25ha. The indicative layout for the area of the site covered by the current draft site allocation replicates that shown on the Framework Masterplan for the planning application 250545.

• An area of community opportunity land in the locality of the existing village hall. This land has been set aside to support the delivery of new community infrastructure should it be required. Bloor Homes are happy to discuss this opportunity with the Council and local stakeholders. Bloor Homes are currently open minded as to the use of this opportunity land and have in their view a positive working relationship with the Parish Council.

• The access strategy provides two points of access, one via Coach Road (as per the proposals agreed by ECC in the determination of planning application 250545) and the other via Old House Road. As set out in the provided Highways Technical Note the proposed access strategy has been subject to pre-application advice with Essex County Council. In addition, the site will integrate successfully with the existing local highway network and existing walking routes. This includes providing a direct link to the existing village hall and its associated facilities. The delivery of an access off Old House Road, will reduce traffic flows on Coach Road by acting as a more direct route for people heading north towards The Causeway and other local routes.

• The Masterplan is landscape led, with the developable area sited in accordance with the findings of the local landscape and heritage assessments.

• Over 7ha of public open space. This is well in excess of the current local policy requirements which requires 10% of the site area to be public open space.

• The public open space provides equipped play space and new walking routes which integrate successfully within existing routes. The existing Public Right of Way (ProW) running through the site will be retained in its current location.

• The retention of existing vegetation and trees provides extensive opportunities to deliver new planning and landscaping.
The aim being to secure on site biodiversity enhancements.

• Set within the public open space is a network of sustainable urban drainage features to ensure that the proposed development does not increase flood risk on site or off-site. These drainage features can be designed to have an amenity and or ecological value.

The land being promoted by Bloor is suitable, achievable and available for development. This is evidenced by the Council’s decision-making in relation to the outline planning application which covers the Land to the north of Coach Road and the further technical and masterplanning work provided in support of these representations.

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 entirety of the site to be allocated for residential development. To demonstrate the robustness of the Masterplan and the overall suitability and deliverability of the site these representations are also supported by a Vision Document and Technical Notes in relation to: Highways, Flood Risk & Drainage, Landscape, Ecology and Heritage.

Bloor Homes will continue to progress their design and technical work and will look to deliver the entire site as soon as practically possible. Bloor Homes will also continue to proactively engage with Great Horkesley Parish Council and would welcome further engagement with the City Council regarding the wider site opportunity and its potential to assist in meeting local housing needs. A formal request for the planning pre-application advice will be submitted to the City Council in early 2026.

In terms of the draft policy wording relating to the existing draft allocation area at Land north of Coach Road, Great Horkesley, Bloor Homes make the following comments:

• The policy does not currently reference the community car park which will be secured via the pending approval of planning application 250545. The delivery of the car park should be written into the policy. The car park, which will assist in alleviating local pressures at peak school drop off/pick up times, impacts upon the developable area available for residential development. This is not currently accounted for in the draft Policy or the Council’s capacity calculations.

• Bloor Homes currently object to development requirements h) and i). In proactively and positively planning for growth the Council have a responsibility to work with their infrastructure partners to ensure growth is deliverable and that there is sufficient capacity at local infrastructure. This work will ensure solutions are in place to support development coming forward at the planning application and implementation stages. Bloor Homes acknowledge the local foul and surface water capacity constraints identified by the POLP and its evidence base. However, it is clear that the Council and Anglian Water have more work to do to plan for growth and agree solutions to existing capacity problems. These solutions should be confirmed by an updated Infrastructure Audit and Delivery Plan at the Pre-Submission stage of the Local Plan process. The current approach of identifying capacity problems with in some cases no firm or costed solution will not support the delivery of growth and thus will jeopardise the Council’s ability to deliver the minimum housing requirement. The Council have a responsibility to work with Anglian Water on these issues as part of preparing the Local Plan.

• The use of a Grampian Condition limiting the occupancy, as per the Council’s current Development Management approach, is not an appropriate or robust strategy to support the delivery of new homes.

Bloor Homes trust that these comments will be taken into account as the Local Plan preparation reaches the Pre-Submission stage in 2026. Bloor Homes also wish to confirm to the Council, that regardless off the emerging proposals for additional development outside of the current draft allocation boundary, that they are committed to delivering up to 150 dwellings on the land which is subject to a resolution to grant planning permission and falls within the current allocation boundary.

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. Great Horkesley falls within the ‘Medium Settlements’ tier, along with twelve other settlements. Bloor Homes support Great Horkesley’s identification as a ‘Medium 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, Great Horkesley is currently assigned to deliver approximately 413 dwellings across two 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 Coach Road for residential development of up to 400 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site.

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 Great Horkesley (and a range of others). Further evidence is required to justify the proposed approach.

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 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.

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 the 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 are the promoter of part of the site proposed for allocation at ‘Land north of Coach Road, Great Horkesley’. In the context of this proposed site allocation for 400 dwellings, Bloor Homes undertook some high-level site capacity work of the allocation area. This work indicates that achieving 400 dwellings across the allocation area is unlikely due to the need to deliver development at an appropriate density, address constraints and the size of the allocation area itself.

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 dwellings 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.
Bloor Homes are promoting land for residential development at ‘Land north of Coach Road, Great Horkesley’. The promotion is supported by technical work and a Vision Document which demonstrates the site’s ability to deliver approximately 400 dwellings alongside public open space and community infrastructure. This site can assist the Council in proposing a robust supply of housing as part of the Local Plan.

Bloor Homes are the promoter of part of the proposed site allocation at Land north of Coach Road, Great Horkesley, as identified on the Proposals Map associated with the Preferred Options Local Plan (POLP).

Bloor Homes are the promoter of the southern field of the two which are covered by the site allocation area. This land has a Strategic Land Availability Assessment (SLAA) reference of ID: 10691. Bloor Homes submitted an outline planning application for up to 150 dwellings and a community car park (Ref: 250545) in March 2025. Following a positive Officer recommendation, the planning application achieved a resolution to grant planning permission at the 27 November 2025 Planning Committee. The planning application process has determined that the site is a suitable location for residential development.

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, this includes the draft allocation Land north of Coach Road, Great Horkesley (Policy PP34).

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, Great Horkesley is a sustainable settlement capable of accommodating housing growth.

Given the evident need for the Council to identify additional land for housing development as part of the Pre-Submission Local Plan, Bloor Homes are promoting additional land to the south of Old House Road, Great Horkesley. The site covers 23.25ha and extends south from Old House Road. The site area includes the land which is subject to a resolution to grant planning permission (Reference: 250545) for 150 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site. Bloor Homes have instructed work to Masterplan this wider opportunity.

A Framework Masterplan covering the entirety of the land promoted by Bloor Homes (including the area covered by application 250545) has been submitted in support of these representations. The Framework Masterplan provides an indicative layout and demonstrates that a site capacity of 400 dwellings is achievable (based on 35 dwellings per hectare). This is the same density accepted by the Council in the determination and assessment of planning application 250545.

The Framework Masterplan delivers the following:

• 400 dwellings across a developable area of 11.25ha. The indicative layout for the area of the site covered by the current draft site allocation replicates that shown on the Framework Masterplan for the planning application 250545.

• An area of community opportunity land in the locality of the existing village hall. This land has been set aside to support the delivery of new community infrastructure should it be required. Bloor Homes are happy to discuss this opportunity with the Council and local stakeholders. Bloor Homes are currently open minded as to the use of this opportunity land and have in their view a positive working relationship with the Parish Council.

• The access strategy provides two points of access, one via Coach Road (as per the proposals agreed by ECC in the determination of planning application 250545) and the other via Old House Road. As set out in the provided Highways Technical Note the proposed access strategy has been subject to pre-application advice with Essex County Council. In addition, the site will integrate successfully with the existing local highway network and existing walking routes. This includes providing a direct link to the existing village hall and its associated facilities. The delivery of an access off Old House Road, will reduce traffic flows on Coach Road by acting as a more direct route for people heading north towards The Causeway and other local routes.

• The Masterplan is landscape led, with the developable area sited in accordance with the findings of the local landscape and heritage assessments.

• Over 7ha of public open space. This is well in excess of the current local policy requirements which requires 10% of the site area to be public open space.

• The public open space provides equipped play space and new walking routes which integrate successfully within existing routes. The existing Public Right of Way (ProW) running through the site will be retained in its current location.

• The retention of existing vegetation and trees provides extensive opportunities to deliver new planning and landscaping.
The aim being to secure on site biodiversity enhancements.

• Set within the public open space is a network of sustainable urban drainage features to ensure that the proposed development does not increase flood risk on site or off-site. These drainage features can be designed to have an amenity and or ecological value.

The land being promoted by Bloor is suitable, achievable and available for development. This is evidenced by the Council’s decision-making in relation to the outline planning application which covers the Land to the north of Coach Road and the further technical and masterplanning work provided in support of these representations.

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 entirety of the site to be allocated for residential development. To demonstrate the robustness of the Masterplan and the overall suitability and deliverability of the site these representations are also supported by a Vision Document and Technical Notes in relation to: Highways, Flood Risk & Drainage, Landscape, Ecology and Heritage.

Bloor Homes will continue to progress their design and technical work and will look to deliver the entire site as soon as practically possible. Bloor Homes will also continue to proactively engage with Great Horkesley Parish Council and would welcome further engagement with the City Council regarding the wider site opportunity and its potential to assist in meeting local housing needs. A formal request for the planning pre-application advice will be submitted to the City Council in early 2026.

In terms of the draft policy wording relating to the existing draft allocation area at Land north of Coach Road, Great Horkesley, Bloor Homes make the following comments:

• The policy does not currently reference the community car park which will be secured via the pending approval of planning application 250545. The delivery of the car park should be written into the policy. The car park, which will assist in alleviating local pressures at peak school drop off/pick up times, impacts upon the developable area available for residential development. This is not currently accounted for in the draft Policy or the Council’s capacity calculations.

• Bloor Homes currently object to development requirements h) and i). In proactively and positively planning for growth the Council have a responsibility to work with their infrastructure partners to ensure growth is deliverable and that there is sufficient capacity at local infrastructure. This work will ensure solutions are in place to support development coming forward at the planning application and implementation stages. Bloor Homes acknowledge the local foul and surface water capacity constraints identified by the POLP and its evidence base. However, it is clear that the Council and Anglian Water have more work to do to plan for growth and agree solutions to existing capacity problems. These solutions should be confirmed by an updated Infrastructure Audit and Delivery Plan at the Pre-Submission stage of the Local Plan process. The current approach of identifying capacity problems with in some cases no firm or costed solution will not support the delivery of growth and thus will jeopardise the Council’s ability to deliver the minimum housing requirement. The Council have a responsibility to work with Anglian Water on these issues as part of preparing the Local Plan.

• The use of a Grampian Condition limiting the occupancy, as per the Council’s current Development Management approach, is not an appropriate or robust strategy to support the delivery of new homes.

Bloor Homes trust that these comments will be taken into account as the Local Plan preparation reaches the Pre-Submission stage in 2026. Bloor Homes also wish to confirm to the Council, that regardless off the emerging proposals for additional development outside of the current draft allocation boundary, that they are committed to delivering up to 150 dwellings on the land which is subject to a resolution to grant planning permission and falls within the current allocation boundary

Bloor Homes are the promoter of part of the proposed site allocation at Land north of Coach Road, Great Horkesley, as identified on the Proposals Map associated with the Preferred Options Local Plan (POLP).

Bloor Homes are the promoter of the southern field of the two which are covered by the site allocation area. This land has a Strategic Land Availability Assessment (SLAA) reference of ID: 10691. Bloor Homes submitted an outline planning application for up to 150 dwellings and a community car park (Ref: 250545) in March 2025. Following a positive Officer recommendation, the planning application achieved a resolution to grant planning permission at the 27 November 2025 Planning Committee. The planning application process has determined that the site is a suitable location for residential development.

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, this includes the draft allocation Land north of Coach Road, Great Horkesley (Policy PP34).

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, Great Horkesley is a sustainable settlement capable of accommodating housing growth.

Given the evident need for the Council to identify additional land for housing development as part of the Pre-Submission Local Plan, Bloor Homes are promoting additional land to the south of Old House Road, Great Horkesley. The site covers 23.25ha and extends south from Old House Road. The site area includes the land which is subject to a resolution to grant planning permission (Reference: 250545) for 150 dwellings. The land promoted by Bloor Homes is within single ownership and control, enabling comprehensive masterplanning, coordinated infrastructure delivery and a clear, deliverable phasing strategy across the entire site. Bloor Homes have instructed work to Masterplan this wider opportunity.

A Framework Masterplan covering the entirety of the land promoted by Bloor Homes (including the area covered by application 250545) has been submitted in support of these representations. The Framework Masterplan provides an indicative layout and demonstrates that a site capacity of 400 dwellings is achievable (based on 35 dwellings per hectare). This is the same density accepted by the Council in the determination and assessment of planning application 250545.

The Framework Masterplan delivers the following:

• 400 dwellings across a developable area of 11.25ha. The indicative layout for the area of the site covered by the current draft site allocation replicates that shown on the Framework Masterplan for the planning application 250545.

• An area of community opportunity land in the locality of the existing village hall. This land has been set aside to support the delivery of new community infrastructure should it be required. Bloor Homes are happy to discuss this opportunity with the Council and local stakeholders. Bloor Homes are currently open minded as to the use of this opportunity land and have in their view a positive working relationship with the Parish Council.

• The access strategy provides two points of access, one via Coach Road (as per the proposals agreed by ECC in the determination of planning application 250545) and the other via Old House Road. As set out in the provided Highways Technical Note the proposed access strategy has been subject to pre-application advice with Essex County Council. In addition, the site will integrate successfully with the existing local highway network and existing walking routes. This includes providing a direct link to the existing village hall and its associated facilities. The delivery of an access off Old House Road, will reduce traffic flows on Coach Road by acting as a more direct route for people heading north towards The Causeway and other local routes.

• The Masterplan is landscape led, with the developable area sited in accordance with the findings of the local landscape and heritage assessments.

• Over 7ha of public open space. This is well in excess of the current local policy requirements which requires 10% of the site area to be public open space.

• The public open space provides equipped play space and new walking routes which integrate successfully within existing routes. The existing Public Right of Way (ProW) running through the site will be retained in its current location.

• The retention of existing vegetation and trees provides extensive opportunities to deliver new planning and landscaping.
The aim being to secure on site biodiversity enhancements.

• Set within the public open space is a network of sustainable urban drainage features to ensure that the proposed development does not increase flood risk on site or off-site. These drainage features can be designed to have an amenity and or ecological value.

The land being promoted by Bloor is suitable, achievable and available for development. This is evidenced by the Council’s decision-making in relation to the outline planning application which covers the Land to the north of Coach Road and the further technical and masterplanning work provided in support of these representations.

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 entirety of the site to be allocated for residential development. To demonstrate the robustness of the Masterplan and the overall suitability and deliverability of the site these representations are also supported by a Vision Document and Technical Notes in relation to: Highways, Flood Risk & Drainage, Landscape, Ecology and Heritage.

Bloor Homes will continue to progress their design and technical work and will look to deliver the entire site as soon as practically possible. Bloor Homes will also continue to proactively engage with Great Horkesley Parish Council and would welcome further engagement with the City Council regarding the wider site opportunity and its potential to assist in meeting local housing needs. A formal request for the planning pre-application advice will be submitted to the City Council in early 2026.

In terms of the draft policy wording relating to the existing draft allocation area at Land north of Coach Road, Great Horkesley, Bloor Homes make the following comments:

• The policy does not currently reference the community car park which will be secured via the pending approval of planning application 250545. The delivery of the car park should be written into the policy. The car park, which will assist in alleviating local pressures at peak school drop off/pick up times, impacts upon the developable area available for residential development. This is not currently accounted for in the draft Policy or the Council’s capacity calculations.

• Bloor Homes currently object to development requirements h) and i). In proactively and positively planning for growth the Council have a responsibility to work with their infrastructure partners to ensure growth is deliverable and that there is sufficient capacity at local infrastructure. This work will ensure solutions are in place to support development coming forward at the planning application and implementation stages. Bloor Homes acknowledge the local foul and surface water capacity constraints identified by the POLP and its evidence base. However, it is clear that the Council and Anglian Water have more work to do to plan for growth and agree solutions to existing capacity problems. These solutions should be confirmed by an updated Infrastructure Audit and Delivery Plan at the Pre-Submission stage of the Local Plan process. The current approach of identifying capacity problems with in some cases no firm or costed solution will not support the delivery of growth and thus will jeopardise the Council’s ability to deliver the minimum housing requirement. The Council have a responsibility to work with Anglian Water on these issues as part of preparing the Local Plan.

• The use of a Grampian Condition limiting the occupancy, as per the Council’s current Development Management approach, is not an appropriate or robust strategy to support the delivery of new homes.

Bloor Homes trust that these comments will be taken into account as the Local Plan preparation reaches the Pre-Submission stage in 2026. Bloor Homes also wish to confirm to the Council, that regardless off the emerging proposals for additional development outside of the current draft allocation boundary, that they are committed to delivering up to 150 dwellings on the land which is subject to a resolution to grant planning permission and falls within the current allocation boundary