Sustainability Appraisal

Langham Parish Council Response to Regulation 18 Local Plan Consultation (Sustainability Appraisal, Appendix C)
Submission 1

Appendix C includes the results of the site sustainability appraisals, but does not offer visibility of the site assessment criteria and assessment methodology, for which one has to visit Appendix D in the Evidence Base. Meaningful consultation must necessarily allow one to comment on the methodology used to produce the results in Appendix C, so this representation focusses on the methodology documented in Appendix D, and in particular the methodology used to assess sustainability measure SA4 for all sites across Colchester.
The scope of sustainability appraisal metric SA4 is to "Reduce the need to travel and promote sustainable and active travel options to reduce congestion".
The only 3 scoring metrics used to assess the level of compliance relate to distances from the nearest rail station, bus stop and cycle route. There are no scoring metrics relating to proximity of likely travel destinations. The scoring methodology is therefore flawed and "one-sided", since all journeys need both a travel mode and a travel destination. This flawed methodology introduces a systemic bias into all the site sustainability appraisals, producing unrealistically favourable results for more rural and remote sites situated far from amenities and essential services.
A better scoring metric for SA4 would be to directly adopt the DfT Connectivity Tool, which considers both travel modes and travel destinations, giving a fairer and far more balanced appraisal. This Connectivity Tool is in fact mandated for use in the draft new NPPF currently out for consultation, so it would make sense for CCC to review and update the Sustainability Appraisal to incorporate this now, because the Secretary of State for Housing announced in December 2025 that once the new NPPF is adopted, any local plans approved under an earlier NPPF that is not consistent with the emerging NPPF (once adopted) will be given very little weight.
If the DfT Connectivity Tool were to be utilised, it would likely call into serious question the soundness of several of the large proposed allocations across Rural North Ward.

Langham Parish Council
13th January 2026

Langham Parish Council Response to Regulation 18 Local Plan Consultation (Sustainability Appraisal, Appendix C)
Submission 2
Appendix C includes the results of the site sustainability appraisals, but does not offer visibility of the site assessment criteria and assessment methodology, for which one has to visit Appendix D in the Evidence Base. Meaningful consultation must necessarily allow one to comment on the methodology used to produce the results in Appendix C, so this representation focusses on the methodology documented in Appendix D, and in particular the methodology used to assess sustainability measure SA5 for the PP37 site allocation.
The scope of sustainability appraisal metric SA5 is to "Promote stronger, more resilient, inclusive communities; improve health and wellbeing; and, reduce levels of deprivation".
A composite assessment of 7 scoring metrics is used to assess the level of compliance, which address in turn:
a) Distance from nearest open space or sports and recreation ground
b) Loss of open space
c) Distance from nearest PRoW
d) Distance from nearest GP surgery
e) Proximity to deprived areas
f) Noise pollution from road and railways
g) Odour
The PP37 site is given a composite + rating across these 7 metrics. Based on the overall scoring schema, we infer that the scores for the individual metrics must have been as follows:
a) ++
b) 0
c) ++
d) –
e) 0
f) 0
g) 0
We would question the validity of the scores for metrics b) and g).
A 0 score for b) would fail to recognise the total loss of open space and rural PRoW network resulting from the allocation.
A 0 score for g) appears totally inconsistent with the stated intention to provide an on-site sewage treatment facility.
We would appreciate clarification of, and an explanation of, the actual scoring used in the sustainability appraisal of metric SA5 for the PP37 site.
It is Langham Parish Council’s view that SA4 and SA5 should have been assessed as – rather than +, in which case the single remaining positively scored metric (out of a total of 14) would be SA1: Housing.
If this is indeed the case, then it calls into question whether due weight has been given to the Sustainability Appraisal when selecting site 10664 for inclusion in the Local Plan.
Langham Parish Council
13th January 2026