Sustainability Appraisal

are writing on behalf of our client, the Defence Infrastructure Organisation (DIO), which is part of the
Ministry of Defence and is responsible for managing the military estate, including the provision of homes
for service personnel across the UK.
We submit representations to the Colchester Regulation 18 Local Plan Consultation covering multiple
DIO-owned sites and strategic concerns regarding the emerging Local Plan. These representations
have been prepared to assist Colchester City Council in developing an effective and deliverable plan
that recognises both local priorities and national defence requirements.
In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and
development plans recognise that MOD Establishments are of strategic military importance to the UK.  It
is important that planning authorities consult with the MOD during the preparation of their plans and take
into account the need to safeguard operational sites.
To support the ongoing military training and operations within the City it is considered that the inclusion
of a specific policy in the Local Plan to recognise these requirements would be beneficial and accord
with national planning policy.
Paragraph 102 of the National Planning Policy Framework (December 2024) states that ‘planning
policies and decisions should promote public safety and take into account wider security and defence
requirements including by ‘b) recognising and supporting development required for operational defence
and security purposes, and ensuring that operational sites are not affected adversely by the impact of
other development proposed in the area.’
Summary of Other Representations
Land South of Birch Brook
Our client is concerned with the proposed designation of this defence land as a Strategic Biodiversity
Area under Policy ST2. We object to this blanket designation which could prevent continued
operational use and future land release requirements, thereby conflicting with national defence
objectives as recognised in NPPF Paragraph 102b.
We also raise significant concerns regarding the spatial strategy's over-reliance on large, complex
strategic allocations in village locations, which introduces substantial delivery risks. We estimate that
approximately 2,970-3,695 dwellings from major strategic allocations are at medium to very high risk
of non-delivery within the Local Plan period. The Plan requires greater flexibility, contingency planning,
and a more diverse range of site sizes and locations to maintain housing supply resilience as supported
by the NPPF.
Middlewick Ranges
Whilst we acknowledge the proposed de-allocation of this 120-hectare site as a housing allocation,
our client objects to the dual designation as both Local Green Space under Policy GN3 and Strategic
Biodiversity Area under Policy ST2. This approach creates unnecessary policy duplication and
potential conflicts that could harm proper ecological management and enhancement.
The Local Green Space designation is also inappropriate for extensive tracts of land where the primary
value lies in biodiversity function rather than recreational or community use, contrary to National
Planning Policy Framework (NPPF) Paragraphs 106-108. We request removal of the Local Green
Space designation to avoid policy confusion and constraints on effective habitat management as
required by the NPPF.
DIO Berechurch
This 3.6 hectare site is being considered for operational defence use, potentially including Service
Family Accommodation (SFA) development to address urgent identified needs. We object to its
proposed inclusion within a Strategic Biodiversity Area designation, which lacks robust evidential
justification and fails to recognise the site's operational importance in accordance with NPPF
Paragraph 102b.
We also highlight that there is an established operational requirement for the site for military purposes,
this includes the need deliver new Service Family Accommodation (SFA) to meet a significant shortfall
in provision in Colchester, yet the Local Plan provides no recognition or policy support for this
requirement contrary to national defence priorities set out in NPPF Paragraph 102b.
The site also contains existing electrical infrastructure and is surrounded by development on three
sides, questioning its suitability as a biodiversity area. We emphasise the need for operational flexibility
to adapt to changing defence requirements without undue policy constraints. We recommend inclusion
of a specific Military Establishments policy to support development that enhances operational
capability and recognise SFA provision as essential workers housing.
Open Space Designations Merville Barracks
Our client objects to the proposed designation of two parcels within our clients’ estates (at Drury
Meadows and Montgomery Estate) as Open Space under Policy GN6. These sites, totalling
approximately 2.17 hectares, are suitable for SFA infill development and do not provide demonstrable
public recreational or amenity value, nor is there funding identified within the Local Plan evidence base
for the long term management and maintenance of this land as open space. The designations lack
robust justification as the sites were not assessed within the Council's Open Space Report (2023),
rendering the approach unsound.
We highlight that there is an urgent need in Colchester to deliver new SFA, yet the Local Plan provides
no recognition or policy support for this requirement contrary to national defence priorities set out in
NPPF Paragraph 102b. We also recommend inclusion of a specific Military Establishments policy to
support development that enhances operational capability and recognise SFA provision as essential
workers housing.
Key Requested Revisions
We respectfully request the following amendments to strengthen the Plan's deliverability and
soundness:
1. Remove Strategic Biodiversity designations from operational defence land (Land South
of Birch Brook and DIO Berechurch).
2. Remove Local Green Space designation from Middlewick Ranges to avoid policy
duplication and given it is an extensive tract of land and therefore unsuitable.
3. Remove Open Space designations from SFA estate land or provide policy flexibility for
SFA development.
4. Include specific policy recognition and support for general defence requirements and
Service Family Accommodation provision.
5. Incorporate greater flexibility and contingency planning within the spatial strategy.
6. Diversify housing supply through a broader range of site sizes and locations.
7. Establish clear triggers for releasing reserve sites to maintain housing supply
resilience.
Conclusion
The DIO remains committed to working collaboratively with Colchester City Council to ensure the
emerging Local Plan provides an appropriate and flexible framework that recognises both local
housing needs and national defence priorities. Our representations seek to strengthen the Plan's
effectiveness, deliverability, and resilience whilst ensuring that essential defence operations can
continue without unnecessary policy constraints.
We believe that addressing these concerns will result in a more robust and sounder Local Plan that
better serves the needs of Colchester's communities whilst fulfilling the Council's obligations to support
national defence requirements.
We look forward to your consideration of these matters and to continued engagement throughout the
Local Plan process.

are writing on behalf of our client, the Defence Infrastructure Organisation (DIO), which is part of the
Ministry of Defence and is responsible for managing the military estate, including the provision of homes
for service personnel across the UK.
We submit representations to the Colchester Regulation 18 Local Plan Consultation covering multiple
DIO-owned sites and strategic concerns regarding the emerging Local Plan. These representations
have been prepared to assist Colchester City Council in developing an effective and deliverable plan
that recognises both local priorities and national defence requirements.
In line with the National Planning Policy Framework (NPPF) it is important that planning authorities and
development plans recognise that MOD Establishments are of strategic military importance to the UK.  It
is important that planning authorities consult with the MOD during the preparation of their plans and take
into account the need to safeguard operational sites.
To support the ongoing military training and operations within the City it is considered that the inclusion
of a specific policy in the Local Plan to recognise these requirements would be beneficial and accord
with national planning policy.
Paragraph 102 of the National Planning Policy Framework (December 2024) states that ‘planning
policies and decisions should promote public safety and take into account wider security and defence
requirements including by ‘b) recognising and supporting development required for operational defence
and security purposes, and ensuring that operational sites are not affected adversely by the impact of
other development proposed in the area.’
Summary of Other Representations
Land South of Birch Brook
Our client is concerned with the proposed designation of this defence land as a Strategic Biodiversity
Area under Policy ST2. We object to this blanket designation which could prevent continued
operational use and future land release requirements, thereby conflicting with national defence
objectives as recognised in NPPF Paragraph 102b.
We also raise significant concerns regarding the spatial strategy's over-reliance on large, complex
strategic allocations in village locations, which introduces substantial delivery risks. We estimate that
approximately 2,970-3,695 dwellings from major strategic allocations are at medium to very high risk
of non-delivery within the Local Plan period. The Plan requires greater flexibility, contingency planning,
and a more diverse range of site sizes and locations to maintain housing supply resilience as supported
by the NPPF.
Middlewick Ranges
Whilst we acknowledge the proposed de-allocation of this 120-hectare site as a housing allocation,
our client objects to the dual designation as both Local Green Space under Policy GN3 and Strategic
Biodiversity Area under Policy ST2. This approach creates unnecessary policy duplication and
potential conflicts that could harm proper ecological management and enhancement.
The Local Green Space designation is also inappropriate for extensive tracts of land where the primary
value lies in biodiversity function rather than recreational or community use, contrary to National
Planning Policy Framework (NPPF) Paragraphs 106-108. We request removal of the Local Green
Space designation to avoid policy confusion and constraints on effective habitat management as
required by the NPPF.
DIO Berechurch
This 3.6 hectare site is being considered for operational defence use, potentially including Service
Family Accommodation (SFA) development to address urgent identified needs. We object to its
proposed inclusion within a Strategic Biodiversity Area designation, which lacks robust evidential
justification and fails to recognise the site's operational importance in accordance with NPPF
Paragraph 102b.
We also highlight that there is an established operational requirement for the site for military purposes,
this includes the need deliver new Service Family Accommodation (SFA) to meet a significant shortfall
in provision in Colchester, yet the Local Plan provides no recognition or policy support for this
requirement contrary to national defence priorities set out in NPPF Paragraph 102b.
The site also contains existing electrical infrastructure and is surrounded by development on three
sides, questioning its suitability as a biodiversity area. We emphasise the need for operational flexibility
to adapt to changing defence requirements without undue policy constraints. We recommend inclusion
of a specific Military Establishments policy to support development that enhances operational
capability and recognise SFA provision as essential workers housing.
Open Space Designations Merville Barracks
Our client objects to the proposed designation of two parcels within our clients’ estates (at Drury
Meadows and Montgomery Estate) as Open Space under Policy GN6. These sites, totalling
approximately 2.17 hectares, are suitable for SFA infill development and do not provide demonstrable
public recreational or amenity value, nor is there funding identified within the Local Plan evidence base
for the long term management and maintenance of this land as open space. The designations lack
robust justification as the sites were not assessed within the Council's Open Space Report (2023),
rendering the approach unsound.
We highlight that there is an urgent need in Colchester to deliver new SFA, yet the Local Plan provides
no recognition or policy support for this requirement contrary to national defence priorities set out in
NPPF Paragraph 102b. We also recommend inclusion of a specific Military Establishments policy to
support development that enhances operational capability and recognise SFA provision as essential
workers housing.
Key Requested Revisions
We respectfully request the following amendments to strengthen the Plan's deliverability and
soundness:
1. Remove Strategic Biodiversity designations from operational defence land (Land South
of Birch Brook and DIO Berechurch).
2. Remove Local Green Space designation from Middlewick Ranges to avoid policy
duplication and given it is an extensive tract of land and therefore unsuitable.
3. Remove Open Space designations from SFA estate land or provide policy flexibility for
SFA development.
4. Include specific policy recognition and support for general defence requirements and
Service Family Accommodation provision.
5. Incorporate greater flexibility and contingency planning within the spatial strategy.
6. Diversify housing supply through a broader range of site sizes and locations.
7. Establish clear triggers for releasing reserve sites to maintain housing supply
resilience.
Conclusion
The DIO remains committed to working collaboratively with Colchester City Council to ensure the
emerging Local Plan provides an appropriate and flexible framework that recognises both local
housing needs and national defence priorities. Our representations seek to strengthen the Plan's
effectiveness, deliverability, and resilience whilst ensuring that essential defence operations can
continue without unnecessary policy constraints.
We believe that addressing these concerns will result in a more robust and sounder Local Plan that
better serves the needs of Colchester's communities whilst fulfilling the Council's obligations to support
national defence requirements.
We look forward to your consideration of these matters and to continued engagement throughout the
Local Plan process.