Langham Housing Development Timeline Report 2019
1. Housing development in Langham
This paper has been prepared as a Timeline of events and activities involving Langham Parish Council
(LPC) covering the period from the Call for Sites phase of the Colchester Borough Council (CBC) Local
Plan in 2015 until September 2019. The new Local Plan (or Emerging Local Plan) covers the period
from 2017 to 2033.
More detailed information on the items summarised can be obtained via the Parish Council Clerk
Carol Harbach.
carolharbach@hotmail.co.uk
2. Local Plan
Local Plan Sections 1 & 2
Section 1 of the new Local Plan is shared by three Councils, Colchester Borough Council, Braintree
District Council and Tendring District Council. Section1 includes policies on cross boundary issues
including infrastructure and housing. It also includes proposals for 3 new garden communities.
Section 2 of the Plan relates to sites for development, housing, employment regeneration solely in
Colchester borough and includes the rural villages such as Langham.
3. Phasing of work for Local Plan Documents - The new Local Plan 2017-2033
CBC is undertaking a thorough review of its adopted policies and allocations which will result in a
new Local Plan to guide development until 2033 and beyond. An Issues and Options consultation
was carried out in January/February 2015, with Preferred Options consultation in summer 2016,
consultation on the Publication Draft in summer 2017, submission of the document to the Secretary
of State in October 2017, and examination hearings of the strategic Section 1 of the plan occurring in
January and May 2018.
The Inspector agreed with the 3 Council’s figures for housing growth of 2,186 during the Plan period
of which 920 were attributed to Colchester. The examination of Section 1 was paused for the
completion of further Sustainability Appraisal and evidence base work, with resumption of the
examination programmed for autumn 2019 and adoption of Section 1 expected Spring 2020 (if
adopted independently). Examination hearings for the Colchester-specific Section 2 of the plan will
follow excepted in Spring/Summer 2020 with adoption of the full plan programmed for winter
2020/21.
4. Activities to date involving LPC and CBC with regard to the Local Plan
4.1 CBC Local Plan “Call for Sites”- July to October 2014 and January to February 2015
Fourteen sites were put forward by landowners in the Langham area for consideration for
housing/commercial development. An additional site was added later although it did form part of
the Langham Garden Village proposal for 4,000 homes that was rejected. That additional site is the
area to the west of Whitnell’s trading estate and was one of the three sites adopted by CBC.
It was made clear at the time that all of the larger villages in Colchester would have to accept
proportional growth in order that that CBC would achieve its housing targets during the plan period.
There has never been a definition of proportional growth and this has been one of the biggest issues
for LPC in its negotiations with CBC over a long period.
4.2 Langham Housing Questionnaire issued by LPC in October 2015
The questionnaire was a comprehensive 16 page document including site location maps and went to
every home in Langham and up to 4 members of each household had the opportunity to make their
views known.
4.3 Analysis of the housing questionnaire issued by LPC in February 2016
Approximately 450 questionnaires were delivered to Langham residents and the response was 174
completed questionnaires. This is a response rate of 43%, which is very good for a questionnaire of
this size and showed that there is a lot of interest in this subject. Obviously not every question was
answered by each responder and in some cases there was a lack of understanding of what was being
asked for. However, it was felt that this sample size was big enough for the Parish Council to draw
conclusions from. The two sites that featured best after backfill and access were considered were
the Wick Road site and the School Road site east of Whitnells. Out of 362 responses Wick Road had
69.3% supporting it and School Road (east of Whitnells) had only 38% support from 358 votes.
However both sites featured well in the extension to the settlement boundary review as did the
School Road site west of Whitnells.
4.4 LPC Public Meeting on CBC Preferred Options July 2016
The meeting was attended by over 70 participants, including the Ward Councillor and Parish
Councillors. There were 49 forms submitted, which amounts to 55 individual responses, as couples
submitted one completed form. The great majority of the comments were very critical of the CBC
Preferred Options for Langham.
Disproportional Growth
This subject elicited most mentions (24), reference being made to the totally disproportionate
growth of 30% proposed for Langham, particularly in relation to other villages in the Borough e.g.
Dedham 2% (now 0%).
School Road
This exercised most respondents, with 12 specific mentions and other comments spread across the
sites submitted. They relate to the already overloaded capacity of School Road, containing three
schools, community centre, recreation ground and local employment zone. References were made
to inadequate drainage and sewage, major congestion, parking issues and the issues raised by 115
(later reduced to 70) proposed housing units having access to School Road, in competition with
current traffic, including heavy goods vehicles.
Inadequate Facilities
There were 10 specific mentions on this subject but other written comments on sustainability
relating to educational provision, healthcare facilities, public transport, slow broadband, weak
mobile phone reception among others
Unsustainable Infrastructure
This elicited 10 specific mentions with other comments spread across the documents, relating to
roads, drainage and sewerage, telephone and broadband.
Size and Density Issues
This elicited 10 specific mentions, although the issue was generally commented upon, in terms of
increased growth (30%), high density of housing, estate style of development, location in already
congested village centre, and change in the special rural character of the village.
Sites to the East and West of Whitnells/Powerplus
These sites were of overwhelming concern to respondents and elicited 62 specific mentions, relating
to size, density, estate style, location, inadequacy of drainage/sewage and change in village
character.
Wick Road
This site was considerably less contentious (although eliciting 29 specific mentions), with comments
suggesting that development of 10 detached properties was proportional, with appropriate infill.
Typical comments were:
Need for Limited Development
There were five specific mentions, mostly relating to the retention of the special rural character of
Langham as a village. Typical comments were:
Village of Special Character
This subject elicited four mentions, relating to the rural character and heritage of Langham, the need
to remain a village and the need for rural not urban style development. Typical comments were:
“Langham is a village of very special character. This needs to be preserved. It is a village with a mix
of housing styles from ancient period dwellings to contemporary buildings and anything in between,
which have evolved piecemeal over a long space of time. Growth needs to be proportional and
appropriate to the nature of the village, not massive and imposed from above”.
4.5 Newsletter Insert August 2016
LPC circulated a flyer to remind residents of the importance of making their views known and
responding to CBC on the Preferred Options for Langham. The deadline date was highlighted and
some of the comments received at the July drop-in session were indicated.
The grossly disproportionate allocation of 125 (Later reduced to 80) properties to the village.
The siting of two estates of 115 (Later reduced to 70) properties in School Road.
The unsustainable and rickety infrastructure, including the overloading of School Road,
inadequate drainage and poor public transport.
The urbanisation of Langham and the destruction of its special rural character.
The density of the proposed housing.
The flyer also made residents aware that LPC were preparing a detailed response to the
consultation, to be published on the village website
The key message was: These proposals will have direct and long-term effects on the whole future of
the village and its quality of life. Please remember that the more responses received the more CBC
will have to sit up and take notice!
4.6 LPC Response to the CBC Local Plan Preferred Options September 2016
This was a 49 page document that went forward to CBC. It included all of the feedback we had
obtained from residents over a long period and also included the questionnaire documents and responses.
Colchester Local Plan Planning Committee –
4.7 “Have Your Say” 6th November 2016
LPC presented the Langham development issues to the Local Plan Committee on 6 November 2016.
4.8 LPC public meeting held on 16th December 2016 (Drop in session)
LPC held a meeting on the 10th December 2016 to get feedback on the three sites that were put
forward by CBC as their Preferred Options for the Langham housing sites that would figure in the
Local Plan covering a period up to 2032.
The meeting was attended by about 70 residents and serious concern was expressed about the
proposed two new housing sites in School Road. One of these sites to the west of Whitnell’s trading
estate had not featured in the Call for Sites phase of the Local Plan preparation, although this land
was included in the much bigger scheme of 4,000 new homes that was not selected by CBC as a
Preferred Option. It is also fair to say that some appetite was shown for an extension to the
settlement boundary at this location when the Langham Housing questionnaire was issued in
October 2015.
At the meeting the point was also made that Langham was not being treated the same as other
villages of a similar size and that their acceptance of new housing figures regarded as “Proportional
Growth” was not reasonable. The point was made that there is no definition of “Proportional
Growth” and Langham’s growth figures were excessive when compared to other villages.
For the purpose of clarity and to get feedback from a bigger sample audience LPC decided to issue a
survey in the form of a mini-questionnaire so that all Langham residents had an opportunity to
comment on the indicative design proposals and to ensure that LPC better understood the local
views so that residents views could be supported.
4.9 Meeting between LPC and CBC Spatial Planning on the 26th January 2017
Discussions took place on the following;
An attempt to get broad agreement to the number of new dwellings to be built in Langham
over the Local Plan Period.
To try and agree where any development should take place. Or where further consultation is
required.
To agree the timeline of a phased programme.
Ensuring both parties are fully up to speed with any infrastructure requirements, site specific
issues and future plans that could affect new development.
4.10 Preferred site options short questionnaire issued March 2017
LPC decided to issue another questionnaire covering the 3 sites selected by CBC in the preferred
options. It was also an opportunity for residents to comment on the new site brought forward to the
west of Whitnells which did not figure as a separate item in the original Call for Sites phase of the
Local Plan.
4.10.1 Content of Questionnaire
This questionnaire showed the layout of proposed housing sites in School Road and to the south end
of Wick Road. The three sites, shown were those selected by CBC as the Preferred Options for
Langham. The initial allocation for Langham in the Preferred Options was 125 new houses over the
Local Plan period to 2032 (later reduced to 80 new houses). The new site to the west of Whitnell’s
industrial site was not introduced at the Call for Sites original deadline so some Langham residents
had not had an opportunity, until this point, of commenting on this option. However, when the
Langham Housing Questionnaire was issued in October 2015 the response showed some appetite for
an extension to the settlement boundary along this section of School Road. The responses also
showed that there was support for up to 85 new homes in Langham during the Local Plan period to
2032. This was based on the larger villages accepting “proportional growth” but Langham has been
targeted for larger growth than other villages of a similar size. Consequently LPC had been trying to
negotiate the numbers down to a figure which could be regarded as balanced, reasonable and
sustainable.
The land area to the west of Whitnell’s site was also included in the much bigger scheme of 4,000
new homes but this was not selected by CBC as a Preferred Option. LPC ran a meeting at the
Community Centre on the 10th December 2016 when residents had an opportunity to comment on
this indicative design and some serious concern was expressed about the proposal. This session was
attended by about 70 local residents.
Clearly the concept was to ensure that LPC could represent the views of residents based on the
information received and other local knowledge acquired.
4.10.2 Results of Questionnaire
The response period ran for about 10 days and residents were asked to return their completed
questionnaires by 7th April 2017. At the deadline date about 110 questionnaires had been received
covering the views of some 200 residents. LPC are expecting more completed questionnaires to be
received after the deadline date and these will be added to the analysis figures although current
observations are unlikely to be affected to any significant degree.
Sample size: 29% of homes, 25% of residents.
This is a good return for a survey over a short response period and provides enough information for
realistic conclusions to be drawn.
Residents were asked whether they would support the indicative design proposals for two sites in
School Road and one site in Wick Road.
Responders 176. 40% said Yes and 60% said No
There were comments on the inadequacies of School Road (10), the sewage/drainage infrastructure
(10) and the excessive and grossly disproportionate number of dwellings proposed (17). Issues of
traffic volume were raised (especially in relation to access and the industrial site in School Road).
Some suggested the re-location of the industrial site to Birchwood Road.
Residents were asked the numbers of new dwellings they would support at each of the three sites.
These have been averaged out to show the following:
New site to the west of School Road - 18 new homes
Site to the east of School Road - 18 new homes
Site to the south of Wick Road - 10 new homes
This would provide 46 new homes over the plan period.
Residents were asked whether they would support a site of up to 20 new homes, fronting Birchwood
Road to the north, as a way of limiting the size of the sites in School Road. This site was given a green
rating by CBC in their site evaluation but was not a Preferred Option.
Responders 173. 66% said Yes and 34% said No.
A number commented that this site was logical for development and would ease congestion in
School Road (5). It was considered to be a safer location (2) although others commented that it was
a busy and hazardous road (3). Some suggested a figure of less than 20 dwellings (4). A preference
was shown for ribbon development.
General Comments from residents about housing sites in Langham
Some commented that the CBC growth proposals were grossly disproportionate (14) and one
considered that growth should be comparable to adjacent sustainable settlements. A number felt
that Langham should retain its special rural character and would be in danger of “urban sprawl” as a
consequence of these proposals (10). Some considered that development should be based on local
need in terms of downsizing, affordability and density of development.
Other comments concerned:
i) “Penny packet” in preference to estate development;
ii) Phased development to 2032;
iii) The need for any growth at all;
iv) The capacity of the primary school;
v) The inadequacies of roads, sewage/drainage and other facilities for development.
4.10.3 Conclusion of Results
There is a real concern that School Road cannot deal with the number of proposed new dwellings
and the associated traffic levels. With regard to traffic, Highways England is of the opinion that
growth of this magnitude in School Road and Wick Road will require major investment on a new A12
junction.
Safety is another key issue for residents as further traffic congestion on School Road will exacerbate
the already problematical issues with regard to the employment zone at the centre of School Road
and the proximity of manoeuvring lorries and heavy plant vehicles to three local Schools and
additional dwellings. Also it is difficult to envisage how the increased number of vehicles can be
integrated into School Road without major congestion, particularly at key times when pupils are
being dropped off or picked up from the Schools.
The issue of Sewage and drainage was a major concern to residents and LPC had held meetings with
both the Environment Agency (EA) and Anglian Water (AW) to try and determine the correct
position with regard to capacity at the Langham Water Recycling Centre. This is a crucial matter
when considering new housing figures which should also incorporate 36 new homes in Boxted as
they use the same Water Recycling Centre.
LPC have been lobbying for a growth figure of up to 50 new homes at the Preferred Options sites,
this number has been endorsed by the Langham residents based on the information received.
4.11 LPC response to Local Pan Consultation June to August 2017
Key areas commented on were:
Unrealistic conclusions on proportionality
Transport and sewage infrastructures
Health and Wellbeing
Educational Facilities
The conclusion was that residents of Langham have accepted that some growth is inevitable on the
assumption that that this growth is fair, proportionate, in the right location, being based on its very
limited facilities and spread over the Plan period to 2033. The Draft Local Plan is sparse in its
supporting evidence and much evidence which should justify their preferred options is missing
thereby highlighting the unsoundness of the document. Highways England and the EA information
also seem weak.
4.12 LPC briefing statement prepared for a meeting with Assistant Director CBC, Mr Dan Gascoyne,
to address the above issues and chart a way forward. Document dated February 2019
LPC asked for a meeting with newly appointed CBC Assistant Director Dan Gascoyne to bring him up
to speed with the extensive discussions undertaken over the last three years with CBC officers on
the currently stalled Local Plan. The serious concerns that current planned developments north of
the A12, current planning applications and approvals, an extended Sustainability Appraisal
(incorporating previously discounted proposals) and the upholding of an appeal by the Planning
Inspector against CBC’s refusal of a planning application, will bring about urban sprawl and the
incorporation of a rural village into urban Colchester. A briefing document was issued and it was
explained that LPC consider that CBC should take a holistic view of current and future planned
developments in Langham and its immediate vicinity, to include a review of infrastructure (or lack of
it) in the village.
The document concluded that it was abundantly clear that current and proposed developments for
Langham with its knock-on effects on surrounding villages north of the A12 will not only serve to
urbanise the whole area but will create a “perfect storm” of environmental, landscape and other
damage to a part of Colchester abutting an Area of Outstanding Natural Beauty and amongst many
listed buildings and picturesque landscape features.
It is doubly unfortunate that the Colchester Local Plan is now stalled at Part 1 stage before Part 2 is
addressed and that the separate hierarchies of Planning Policy, Planning Services and Building
Control within the Borough Council appear unable to take a holistic view of what is happening now
and in the future. Co-ordination with the County Council Highways, Highways England and the
Environment Agency also seems weak.
4.13 LPC Meeting with Dan Gascoyne Assistant Director CBC and Karen Syrett Planning & Housing
Manager CBC. 25th February 2019
The main purpose of the meeting was to bring Dan Gascoyne up to speed with the Langham issues
and to determine whether there were any developments that had changed LPC’s understanding of
the situation. One key thing that came out of this was that Karen Syrett now has responsibility for
planning policy and development management (planning applications). Which was a good thing as it
would enable CBC to now take a more holistic view of planning. We talked about the big concerns of
Langham residents and also about speculative planning applications coming through in the delay
period where no Local Plan numbers had been agreed. It was made clear by CBC that Colchester still
have a 5 year housing supply and that those planning submissions, that were a preferred option in
the stalled Local Plan, would be looked at more favourably than speculative requests.
4.14 The Common theme put forward by LPC to CBC
Grossly disproportionate growth (34%) compared with other settlements AND in its own terms.
Proportionate growth has been democratically supported via public meetings and questionnaires
findings but has produced no sympathetic response from CBC.
Essential infrastructure needs not met, a WRC already vastly exceeding existing capacity with missing
evidence across other areas. No modelling work done on the impact of over 100 new homes in
School Road exacerbating congestion in a dangerous area with vulnerable people
Urban solution of backfill ‘estate’ type development on 2 of the 3 rural sites identified destroying
special rural historic character of Langham, a village in the project area of the Dedham Vale AONB.
5. LPC Meetings involving Anglian Water (AW) and/or the Environment Agency (EA) to discuss
drainage/sewage issues in Langham.
In 2017 the EA were of the opinion that AW was breaching their current permit based on Q80 Dry
Weather Flow readings which are used for planning purposes. AW was of the opinion that they are
not breaching their permit as the use a different set of parameters, Q90 Dry Weather Flow, which
are used for compliance. EA’s stance was that Langham was already oversubscribed to the tune of
133 homes and significant investment was likely to be required to cater for the current and new
growth estimates. This was likely to pose a problem for short term housing growth and would
provide a natural phasing over the plan period which has been a key requirement for Langham
residents. AW agreed to work with the EA to provide a common view that will be presented to CBC
as an updated input to the Local Plan.
LPC had been lobbying for a growth figure of up to 50 new homes at the Preferred Options sites; this
number has been endorsed by the Langham residents based on the information received.
5.1 LPC meeting with EA held at Iceni House, Ipswich on 5th January 2017.
LPC explained the background with regard to the Local Plan process and the various events that have
occurred starting from the maximum land grab (10,000 homes) to the most recent discussions on
the Preferred Options.
They see themselves as a statutory consultee for things like the Local Plan and as a regulator for
organisations such as Anglian Water, who have to comply with the permits that the EA issues to
them. They also have a responsibility for enforcement activities when organisations such as AW are
non-compliant with regard to operating within their permit guidelines. As a general point they said
that they would have liked to see more comments in the Local Plan document which covered their
input. They would not expect to see site layouts or planning requests at any level and see this as a
debate between CBC, the developer/landowner and Anglian Water.
Permits
AW is currently working on a permit which runs from 2015 to 2020. Each treatment works has a
maximum flow level and has to comply with chemical levels in the water. The dry weather maximum
flow (actual volumes) appears in the Langham/Boxted permit. Water discharges to the Blackbrook
and then on to the Stour. Langham sewage works is oversubscribed to the tune of 133 homes. EA at
the time of the meeting EA were deciding whether they need to issue an enforcement order to AW
for the Langham plant.
Here is the interesting point. Any expansion of the flow (i.e. increased housing) means that all of the
water would need to be treated to a higher standard as the overall volume of water at the Stour
must not deteriorate in quality. Secondly, they are currently trying to reduce Phosphate levels in the
Stour not just maintain them at the existing level. To do both of these things two treatment works
upstream and the Langham plant need to be upgraded. The upstream works are being carried out at
the moment.
Funds for a Langham upgrade were not likely to be available before 2026 and the process involves
the Asset management Programme (AMP). The bill payer’s contribution and the financial model
need to be vetted by OFWAT and agreement given. It was understood that no work was being done
on this by AW at that point in time. The cost for this (whole life treatment over 35 years) could be in
the region of £5-£10million. There may also be a network issue in terms of how the sewage is
delivered to the treatment plant. Not an attractive proposition for AW and any contribution by
developers would need to be a significant sum.
AW has a duty to accept domestic sewage and the issue then becomes compliance with their permit.
They are then at loggerheads with the EA resulting in very difficult meetings. EA are adamant that
developments must not come before improvements in the system. They require a certainty that
the improvement work will be carried out first.
Other ways of dealing with foul water drainage.
It was assumed that Langham has a combined system of foul water and surface water drainage.
When confronted with a foul water capacity issue other solutions are available (Cess pit, Septic tank,
package treatment plant). All of these are non-mains solutions. However the EA have a policy that in
areas where mains sewage is available they will not sanction non-mains sewage solutions. No
capacity now, is not a reason to move to a non-mains solution. Another option would be to put in a
pipeline and pump everything to the Colchester network which has plenty of capacity. Their waste
discharges in the Colne just below the tidal limit. This may well have serious cost implications as well
as land issues in routing the pipeline.
Current Flooding in Langham involving foul water containment.
It was agreed that putting in non-return valves was not an elegant way of addressing this issue as the
water will inevitably escape somewhere if the network cannot deal with the capacity. EA can only
deal with this as part of any permit enforcement discussions. As expected their view was that this
needs to be addressed directly with AW as foul drainage capacity does not come under their remit.
Ground water infiltration
This can be a big problem during heavy rain periods and over time can seriously affect the volumes
of water being treated. Lining of the pipes can stop ground water infiltration into the pipework and
we think this was carried out in School Road.
Location of Ponds on site plans for surface water drainage
It was stated by EA that ponds could only realistically take the run off from the roofs on new houses.
If ponds are being put forward for SuDS there should be a detailed calculation that can be assessed.
Water levels will vary as the base of any pond will be gravel and during the dry months the pond will
just be dried reeds and mud. There could be a benefit to help with any existing surface water issues
but this is not an elegant solution.
Local Plan Policy SS11
The key deliverables stated in the Local Plan SS11 section on Langham it states that development
will be supported which provides:
- Adequate wastewater treatment and sewage infrastructure capacity in the catchment area
- Appropriate SuDS for managing surface water runoff within the overall design and layout of the
site.
It was agreed by all parties that we should insist on a statement of how SS11 can be delivered with
timescales.
5.2 LPC meeting with AW 14 February 2017
Key Points from the meeting:
AW is a statutory consultee on Local Plans and Neighbourhood Plans. They get involved in planning
applications when asked usually with major developments which are 10 or more dwellings.
There are two key areas in the infrastructure.
Sewage Infrastructure - Developers fund connection to the existing network and only fund their
site(s). If there are any existing issues with the infrastructure AW need to resolve and fund this. They
would need to build costs into the Asset management Period 7, 2020-2025.
Water Recycling Centre – AW said there was capacity at Langham for growth but that might mean
that kit on the ground could be improved or alternatively a simple solution. They do not reserve
capacity so look at each request when it comes forward. This could be a bit of a free for all if more
than one site comes forward at the same time. CBC is therefore being asked for a phased
introduction. AW said that the pipe network was the issue for Langham and they were performing
against their permit requirements. This point needed be clarified by AW as the EA were of the
opinion that this was not the case and they were oversubscribed to the tune of 133 homes. LPC
asked whether we could have a joint meeting with AW and the EA. AW thought this may be possible
and said she would check this.
AW is working with the local authority on a phased number of new dwellings (as an example 50
homes per annum was mentioned) for their 5 year cycle. Any increases in prices need to be agreed
with OFWAT if funding is required to expand or maintain their network.
AW is working with the numbers in the preferred options consultation which is 125 new homes.
They work on flow rates for standard homes or B1 businesses which is a different rate. There could
be limited capacity and infrastructure work could be needed. AW engineers look at network capacity
and the Water Recycling Station. The network effectiveness was affected by the pumping station
performance, what we flush and may need washing out.
AW is broken down into;
- Engineering growth and planning
- Environmental team
- Operations growth, field work on planning
- Future growth
The point about developer’s costs for network connection was discussed and could vary if they run
out of network connection points and an offsite connection is required. Developers could also end
up with planning conditions on foul sewage. It was made clear that any new development should not
affect any existing customers.
We discussed SuDs and AW is clear that this was not their responsibility. They try to ensure that
SuDs does not enter their network although they are prepared to adopt sustainable drainage
systems if their standards are met. They agreed to provide us information or access to a website for
information on this issue. LPC thought that this could be the right approach rather that ponds to
take SuDs which is not an elegant solution.
LPC asked about the updated water cycle study and were told this had been updated by a
consultant. It was agreed that we did not know where we are with this information.
We briefly discussed the concept of piping sewage back to Colchester but this would require
modelling and investment and was not an easy thing to do. We also touched on the operations team
fitting non-return valves but this was put down to the network requirements not any capacity
problems with the Water Recycling Centre.
5.3 LPC meeting with EA and AW (on audio conference) at Iceni House Ipswich on 23rd March 2017.
The 420 Dry Weather Flow (DWF) permit figure issued to AW by EA is 420 cubic metres per day.
They can't easily measure DWF any more so they are now using statistical means, which in our view is
causing a lot of confusion.
They have ended up with two sets of flow rates Q80 and Q90
Q80 is used for planning figures
Q90 is used for compliance
Q90 is less than Q80
Taking an example of the Q90 measured flow in 2015. AW is quoting 382 cubic metres per day against a
permit figure of 420. So they are saying they are compliant. 382 cubic metres per day measured in Q80
format would convert to 436 cubic metres per day. So from a planning perspective they are non-
compliant. The much higher figures of Q90 522 cubic metres per day in 2014 are being
defended by high SuDs egress into the network, and a faulty pump reading. Both of these issues have
apparently been addressed by recent work. So AW says the original response to CBC for the Local Plan
was based on old incorrect data. EA still believe that AW is technically breaking their permit but there is
no enforcement. EA still maintain there should be nil growth. One thing is clear; you can understand why
they don't agree.
AW had a new business plan in preparation 2020-2025, there would also be a plan for longer term waste
water issues and strategy that will feed into the business plan.
The Water Cycle Study is undertaken by consultants, the last one was 2010.
EA made a comment after AW left the meeting. As a private company AW is being told they should
accept new customers and should not stand in the way of development.
Actions that came out of the meeting:
1. AW would work with EA for a common view which would be the basis for an updated response to CBC
for the Local Plan. (We agreed with EA after AW left the meeting that LPC would get sight of this for
comment before it was sent forward).
2. AW would check what has been said to Langham developers and in what context or on what basis it
has been said.
3. EA will provide information on quality parameters i.e. bringing down the phosphate limits by 1mg per
litre of water for x new houses being built. EA will cover the impact of up to 10 new homes then up to 50
new homes and finally up to 125 new homes (including impact on flow rates). This can then
indicate what a new DWF permit might look like.
4. AW will check on progress of the latest Water Cycle Study that will feed the Local Plan and will provide
more information before the consultation phase.
5. AW said they would report back on what specific blockages in the network were worked on and
cleared for Langham.
5.4 Joint Positioning Statement on growth at WRC catchments in the Colchester area - September 2017
After significant lobbying by LPC a joint positioning statement was issued by CBC, AW and EA. The
statement set out the current position relating to the capacity of Langham WRC following the
publication of the Colchester Borough Water Cycle Study (WCS) in December 2016.
The conclusions of this document were that planning applications for development connected to
Langham & Dedham WRCs require careful waste water infrastructure and water quality
consideration to ensure that the objectives of the Water Framework Directive are not compromised.
The timing of development will play a crucial part in this, ensuring that developments are not
progressed ahead of improvements in treatment technology capabilities or the identification of
alternative approaches, to ensure the environment is protected. The relevant Local Plan policies for
development at Langham and Boxted include this requirement.
Anglian Water will continue to monitor the quantity and quality of flows from WRCs in the
Colchester area including Langham (East) and Dedham and will take the necessary steps at the
appropriate time in order to accommodate growth within environmental parameters. Further work
needs to be done to consider and identify all the improvements that will need to be implemented to
enable development to proceed. Given the ongoing nature of the work it should be recognised that
improvements may not be delivered during the earliest stage of the plan.
Langham Parish Council August 2019
This paper has been prepared as a Timeline of events and activities involving Langham Parish Council
(LPC) covering the period from the Call for Sites phase of the Colchester Borough Council (CBC) Local
Plan in 2015 until September 2019. The new Local Plan (or Emerging Local Plan) covers the period
from 2017 to 2033.
More detailed information on the items summarised can be obtained via the Parish Council Clerk
Carol Harbach.
carolharbach@hotmail.co.uk
2. Local Plan
Local Plan Sections 1 & 2
Section 1 of the new Local Plan is shared by three Councils, Colchester Borough Council, Braintree
District Council and Tendring District Council. Section1 includes policies on cross boundary issues
including infrastructure and housing. It also includes proposals for 3 new garden communities.
Section 2 of the Plan relates to sites for development, housing, employment regeneration solely in
Colchester borough and includes the rural villages such as Langham.
3. Phasing of work for Local Plan Documents - The new Local Plan 2017-2033
CBC is undertaking a thorough review of its adopted policies and allocations which will result in a
new Local Plan to guide development until 2033 and beyond. An Issues and Options consultation
was carried out in January/February 2015, with Preferred Options consultation in summer 2016,
consultation on the Publication Draft in summer 2017, submission of the document to the Secretary
of State in October 2017, and examination hearings of the strategic Section 1 of the plan occurring in
January and May 2018.
The Inspector agreed with the 3 Council’s figures for housing growth of 2,186 during the Plan period
of which 920 were attributed to Colchester. The examination of Section 1 was paused for the
completion of further Sustainability Appraisal and evidence base work, with resumption of the
examination programmed for autumn 2019 and adoption of Section 1 expected Spring 2020 (if
adopted independently). Examination hearings for the Colchester-specific Section 2 of the plan will
follow excepted in Spring/Summer 2020 with adoption of the full plan programmed for winter
2020/21.
4. Activities to date involving LPC and CBC with regard to the Local Plan
4.1 CBC Local Plan “Call for Sites”- July to October 2014 and January to February 2015
Fourteen sites were put forward by landowners in the Langham area for consideration for
housing/commercial development. An additional site was added later although it did form part of
the Langham Garden Village proposal for 4,000 homes that was rejected. That additional site is the
area to the west of Whitnell’s trading estate and was one of the three sites adopted by CBC.
It was made clear at the time that all of the larger villages in Colchester would have to accept
proportional growth in order that that CBC would achieve its housing targets during the plan period.
There has never been a definition of proportional growth and this has been one of the biggest issues
for LPC in its negotiations with CBC over a long period.
4.2 Langham Housing Questionnaire issued by LPC in October 2015
The questionnaire was a comprehensive 16 page document including site location maps and went to
every home in Langham and up to 4 members of each household had the opportunity to make their
views known.
4.3 Analysis of the housing questionnaire issued by LPC in February 2016
Approximately 450 questionnaires were delivered to Langham residents and the response was 174
completed questionnaires. This is a response rate of 43%, which is very good for a questionnaire of
this size and showed that there is a lot of interest in this subject. Obviously not every question was
answered by each responder and in some cases there was a lack of understanding of what was being
asked for. However, it was felt that this sample size was big enough for the Parish Council to draw
conclusions from. The two sites that featured best after backfill and access were considered were
the Wick Road site and the School Road site east of Whitnells. Out of 362 responses Wick Road had
69.3% supporting it and School Road (east of Whitnells) had only 38% support from 358 votes.
However both sites featured well in the extension to the settlement boundary review as did the
School Road site west of Whitnells.
4.4 LPC Public Meeting on CBC Preferred Options July 2016
The meeting was attended by over 70 participants, including the Ward Councillor and Parish
Councillors. There were 49 forms submitted, which amounts to 55 individual responses, as couples
submitted one completed form. The great majority of the comments were very critical of the CBC
Preferred Options for Langham.
Disproportional Growth
This subject elicited most mentions (24), reference being made to the totally disproportionate
growth of 30% proposed for Langham, particularly in relation to other villages in the Borough e.g.
Dedham 2% (now 0%).
School Road
This exercised most respondents, with 12 specific mentions and other comments spread across the
sites submitted. They relate to the already overloaded capacity of School Road, containing three
schools, community centre, recreation ground and local employment zone. References were made
to inadequate drainage and sewage, major congestion, parking issues and the issues raised by 115
(later reduced to 70) proposed housing units having access to School Road, in competition with
current traffic, including heavy goods vehicles.
Inadequate Facilities
There were 10 specific mentions on this subject but other written comments on sustainability
relating to educational provision, healthcare facilities, public transport, slow broadband, weak
mobile phone reception among others
Unsustainable Infrastructure
This elicited 10 specific mentions with other comments spread across the documents, relating to
roads, drainage and sewerage, telephone and broadband.
Size and Density Issues
This elicited 10 specific mentions, although the issue was generally commented upon, in terms of
increased growth (30%), high density of housing, estate style of development, location in already
congested village centre, and change in the special rural character of the village.
Sites to the East and West of Whitnells/Powerplus
These sites were of overwhelming concern to respondents and elicited 62 specific mentions, relating
to size, density, estate style, location, inadequacy of drainage/sewage and change in village
character.
Wick Road
This site was considerably less contentious (although eliciting 29 specific mentions), with comments
suggesting that development of 10 detached properties was proportional, with appropriate infill.
Typical comments were:
Need for Limited Development
There were five specific mentions, mostly relating to the retention of the special rural character of
Langham as a village. Typical comments were:
Village of Special Character
This subject elicited four mentions, relating to the rural character and heritage of Langham, the need
to remain a village and the need for rural not urban style development. Typical comments were:
“Langham is a village of very special character. This needs to be preserved. It is a village with a mix
of housing styles from ancient period dwellings to contemporary buildings and anything in between,
which have evolved piecemeal over a long space of time. Growth needs to be proportional and
appropriate to the nature of the village, not massive and imposed from above”.
4.5 Newsletter Insert August 2016
LPC circulated a flyer to remind residents of the importance of making their views known and
responding to CBC on the Preferred Options for Langham. The deadline date was highlighted and
some of the comments received at the July drop-in session were indicated.
The grossly disproportionate allocation of 125 (Later reduced to 80) properties to the village.
The siting of two estates of 115 (Later reduced to 70) properties in School Road.
The unsustainable and rickety infrastructure, including the overloading of School Road,
inadequate drainage and poor public transport.
The urbanisation of Langham and the destruction of its special rural character.
The density of the proposed housing.
The flyer also made residents aware that LPC were preparing a detailed response to the
consultation, to be published on the village website
The key message was: These proposals will have direct and long-term effects on the whole future of
the village and its quality of life. Please remember that the more responses received the more CBC
will have to sit up and take notice!
4.6 LPC Response to the CBC Local Plan Preferred Options September 2016
This was a 49 page document that went forward to CBC. It included all of the feedback we had
obtained from residents over a long period and also included the questionnaire documents and responses.
Colchester Local Plan Planning Committee –
4.7 “Have Your Say” 6th November 2016
LPC presented the Langham development issues to the Local Plan Committee on 6 November 2016.
4.8 LPC public meeting held on 16th December 2016 (Drop in session)
LPC held a meeting on the 10th December 2016 to get feedback on the three sites that were put
forward by CBC as their Preferred Options for the Langham housing sites that would figure in the
Local Plan covering a period up to 2032.
The meeting was attended by about 70 residents and serious concern was expressed about the
proposed two new housing sites in School Road. One of these sites to the west of Whitnell’s trading
estate had not featured in the Call for Sites phase of the Local Plan preparation, although this land
was included in the much bigger scheme of 4,000 new homes that was not selected by CBC as a
Preferred Option. It is also fair to say that some appetite was shown for an extension to the
settlement boundary at this location when the Langham Housing questionnaire was issued in
October 2015.
At the meeting the point was also made that Langham was not being treated the same as other
villages of a similar size and that their acceptance of new housing figures regarded as “Proportional
Growth” was not reasonable. The point was made that there is no definition of “Proportional
Growth” and Langham’s growth figures were excessive when compared to other villages.
For the purpose of clarity and to get feedback from a bigger sample audience LPC decided to issue a
survey in the form of a mini-questionnaire so that all Langham residents had an opportunity to
comment on the indicative design proposals and to ensure that LPC better understood the local
views so that residents views could be supported.
4.9 Meeting between LPC and CBC Spatial Planning on the 26th January 2017
Discussions took place on the following;
An attempt to get broad agreement to the number of new dwellings to be built in Langham
over the Local Plan Period.
To try and agree where any development should take place. Or where further consultation is
required.
To agree the timeline of a phased programme.
Ensuring both parties are fully up to speed with any infrastructure requirements, site specific
issues and future plans that could affect new development.
4.10 Preferred site options short questionnaire issued March 2017
LPC decided to issue another questionnaire covering the 3 sites selected by CBC in the preferred
options. It was also an opportunity for residents to comment on the new site brought forward to the
west of Whitnells which did not figure as a separate item in the original Call for Sites phase of the
Local Plan.
4.10.1 Content of Questionnaire
This questionnaire showed the layout of proposed housing sites in School Road and to the south end
of Wick Road. The three sites, shown were those selected by CBC as the Preferred Options for
Langham. The initial allocation for Langham in the Preferred Options was 125 new houses over the
Local Plan period to 2032 (later reduced to 80 new houses). The new site to the west of Whitnell’s
industrial site was not introduced at the Call for Sites original deadline so some Langham residents
had not had an opportunity, until this point, of commenting on this option. However, when the
Langham Housing Questionnaire was issued in October 2015 the response showed some appetite for
an extension to the settlement boundary along this section of School Road. The responses also
showed that there was support for up to 85 new homes in Langham during the Local Plan period to
2032. This was based on the larger villages accepting “proportional growth” but Langham has been
targeted for larger growth than other villages of a similar size. Consequently LPC had been trying to
negotiate the numbers down to a figure which could be regarded as balanced, reasonable and
sustainable.
The land area to the west of Whitnell’s site was also included in the much bigger scheme of 4,000
new homes but this was not selected by CBC as a Preferred Option. LPC ran a meeting at the
Community Centre on the 10th December 2016 when residents had an opportunity to comment on
this indicative design and some serious concern was expressed about the proposal. This session was
attended by about 70 local residents.
Clearly the concept was to ensure that LPC could represent the views of residents based on the
information received and other local knowledge acquired.
4.10.2 Results of Questionnaire
The response period ran for about 10 days and residents were asked to return their completed
questionnaires by 7th April 2017. At the deadline date about 110 questionnaires had been received
covering the views of some 200 residents. LPC are expecting more completed questionnaires to be
received after the deadline date and these will be added to the analysis figures although current
observations are unlikely to be affected to any significant degree.
Sample size: 29% of homes, 25% of residents.
This is a good return for a survey over a short response period and provides enough information for
realistic conclusions to be drawn.
Residents were asked whether they would support the indicative design proposals for two sites in
School Road and one site in Wick Road.
Responders 176. 40% said Yes and 60% said No
There were comments on the inadequacies of School Road (10), the sewage/drainage infrastructure
(10) and the excessive and grossly disproportionate number of dwellings proposed (17). Issues of
traffic volume were raised (especially in relation to access and the industrial site in School Road).
Some suggested the re-location of the industrial site to Birchwood Road.
Residents were asked the numbers of new dwellings they would support at each of the three sites.
These have been averaged out to show the following:
New site to the west of School Road - 18 new homes
Site to the east of School Road - 18 new homes
Site to the south of Wick Road - 10 new homes
This would provide 46 new homes over the plan period.
Residents were asked whether they would support a site of up to 20 new homes, fronting Birchwood
Road to the north, as a way of limiting the size of the sites in School Road. This site was given a green
rating by CBC in their site evaluation but was not a Preferred Option.
Responders 173. 66% said Yes and 34% said No.
A number commented that this site was logical for development and would ease congestion in
School Road (5). It was considered to be a safer location (2) although others commented that it was
a busy and hazardous road (3). Some suggested a figure of less than 20 dwellings (4). A preference
was shown for ribbon development.
General Comments from residents about housing sites in Langham
Some commented that the CBC growth proposals were grossly disproportionate (14) and one
considered that growth should be comparable to adjacent sustainable settlements. A number felt
that Langham should retain its special rural character and would be in danger of “urban sprawl” as a
consequence of these proposals (10). Some considered that development should be based on local
need in terms of downsizing, affordability and density of development.
Other comments concerned:
i) “Penny packet” in preference to estate development;
ii) Phased development to 2032;
iii) The need for any growth at all;
iv) The capacity of the primary school;
v) The inadequacies of roads, sewage/drainage and other facilities for development.
4.10.3 Conclusion of Results
There is a real concern that School Road cannot deal with the number of proposed new dwellings
and the associated traffic levels. With regard to traffic, Highways England is of the opinion that
growth of this magnitude in School Road and Wick Road will require major investment on a new A12
junction.
Safety is another key issue for residents as further traffic congestion on School Road will exacerbate
the already problematical issues with regard to the employment zone at the centre of School Road
and the proximity of manoeuvring lorries and heavy plant vehicles to three local Schools and
additional dwellings. Also it is difficult to envisage how the increased number of vehicles can be
integrated into School Road without major congestion, particularly at key times when pupils are
being dropped off or picked up from the Schools.
The issue of Sewage and drainage was a major concern to residents and LPC had held meetings with
both the Environment Agency (EA) and Anglian Water (AW) to try and determine the correct
position with regard to capacity at the Langham Water Recycling Centre. This is a crucial matter
when considering new housing figures which should also incorporate 36 new homes in Boxted as
they use the same Water Recycling Centre.
LPC have been lobbying for a growth figure of up to 50 new homes at the Preferred Options sites,
this number has been endorsed by the Langham residents based on the information received.
4.11 LPC response to Local Pan Consultation June to August 2017
Key areas commented on were:
Unrealistic conclusions on proportionality
Transport and sewage infrastructures
Health and Wellbeing
Educational Facilities
The conclusion was that residents of Langham have accepted that some growth is inevitable on the
assumption that that this growth is fair, proportionate, in the right location, being based on its very
limited facilities and spread over the Plan period to 2033. The Draft Local Plan is sparse in its
supporting evidence and much evidence which should justify their preferred options is missing
thereby highlighting the unsoundness of the document. Highways England and the EA information
also seem weak.
4.12 LPC briefing statement prepared for a meeting with Assistant Director CBC, Mr Dan Gascoyne,
to address the above issues and chart a way forward. Document dated February 2019
LPC asked for a meeting with newly appointed CBC Assistant Director Dan Gascoyne to bring him up
to speed with the extensive discussions undertaken over the last three years with CBC officers on
the currently stalled Local Plan. The serious concerns that current planned developments north of
the A12, current planning applications and approvals, an extended Sustainability Appraisal
(incorporating previously discounted proposals) and the upholding of an appeal by the Planning
Inspector against CBC’s refusal of a planning application, will bring about urban sprawl and the
incorporation of a rural village into urban Colchester. A briefing document was issued and it was
explained that LPC consider that CBC should take a holistic view of current and future planned
developments in Langham and its immediate vicinity, to include a review of infrastructure (or lack of
it) in the village.
The document concluded that it was abundantly clear that current and proposed developments for
Langham with its knock-on effects on surrounding villages north of the A12 will not only serve to
urbanise the whole area but will create a “perfect storm” of environmental, landscape and other
damage to a part of Colchester abutting an Area of Outstanding Natural Beauty and amongst many
listed buildings and picturesque landscape features.
It is doubly unfortunate that the Colchester Local Plan is now stalled at Part 1 stage before Part 2 is
addressed and that the separate hierarchies of Planning Policy, Planning Services and Building
Control within the Borough Council appear unable to take a holistic view of what is happening now
and in the future. Co-ordination with the County Council Highways, Highways England and the
Environment Agency also seems weak.
4.13 LPC Meeting with Dan Gascoyne Assistant Director CBC and Karen Syrett Planning & Housing
Manager CBC. 25th February 2019
The main purpose of the meeting was to bring Dan Gascoyne up to speed with the Langham issues
and to determine whether there were any developments that had changed LPC’s understanding of
the situation. One key thing that came out of this was that Karen Syrett now has responsibility for
planning policy and development management (planning applications). Which was a good thing as it
would enable CBC to now take a more holistic view of planning. We talked about the big concerns of
Langham residents and also about speculative planning applications coming through in the delay
period where no Local Plan numbers had been agreed. It was made clear by CBC that Colchester still
have a 5 year housing supply and that those planning submissions, that were a preferred option in
the stalled Local Plan, would be looked at more favourably than speculative requests.
4.14 The Common theme put forward by LPC to CBC
Grossly disproportionate growth (34%) compared with other settlements AND in its own terms.
Proportionate growth has been democratically supported via public meetings and questionnaires
findings but has produced no sympathetic response from CBC.
Essential infrastructure needs not met, a WRC already vastly exceeding existing capacity with missing
evidence across other areas. No modelling work done on the impact of over 100 new homes in
School Road exacerbating congestion in a dangerous area with vulnerable people
Urban solution of backfill ‘estate’ type development on 2 of the 3 rural sites identified destroying
special rural historic character of Langham, a village in the project area of the Dedham Vale AONB.
5. LPC Meetings involving Anglian Water (AW) and/or the Environment Agency (EA) to discuss
drainage/sewage issues in Langham.
In 2017 the EA were of the opinion that AW was breaching their current permit based on Q80 Dry
Weather Flow readings which are used for planning purposes. AW was of the opinion that they are
not breaching their permit as the use a different set of parameters, Q90 Dry Weather Flow, which
are used for compliance. EA’s stance was that Langham was already oversubscribed to the tune of
133 homes and significant investment was likely to be required to cater for the current and new
growth estimates. This was likely to pose a problem for short term housing growth and would
provide a natural phasing over the plan period which has been a key requirement for Langham
residents. AW agreed to work with the EA to provide a common view that will be presented to CBC
as an updated input to the Local Plan.
LPC had been lobbying for a growth figure of up to 50 new homes at the Preferred Options sites; this
number has been endorsed by the Langham residents based on the information received.
5.1 LPC meeting with EA held at Iceni House, Ipswich on 5th January 2017.
LPC explained the background with regard to the Local Plan process and the various events that have
occurred starting from the maximum land grab (10,000 homes) to the most recent discussions on
the Preferred Options.
They see themselves as a statutory consultee for things like the Local Plan and as a regulator for
organisations such as Anglian Water, who have to comply with the permits that the EA issues to
them. They also have a responsibility for enforcement activities when organisations such as AW are
non-compliant with regard to operating within their permit guidelines. As a general point they said
that they would have liked to see more comments in the Local Plan document which covered their
input. They would not expect to see site layouts or planning requests at any level and see this as a
debate between CBC, the developer/landowner and Anglian Water.
Permits
AW is currently working on a permit which runs from 2015 to 2020. Each treatment works has a
maximum flow level and has to comply with chemical levels in the water. The dry weather maximum
flow (actual volumes) appears in the Langham/Boxted permit. Water discharges to the Blackbrook
and then on to the Stour. Langham sewage works is oversubscribed to the tune of 133 homes. EA at
the time of the meeting EA were deciding whether they need to issue an enforcement order to AW
for the Langham plant.
Here is the interesting point. Any expansion of the flow (i.e. increased housing) means that all of the
water would need to be treated to a higher standard as the overall volume of water at the Stour
must not deteriorate in quality. Secondly, they are currently trying to reduce Phosphate levels in the
Stour not just maintain them at the existing level. To do both of these things two treatment works
upstream and the Langham plant need to be upgraded. The upstream works are being carried out at
the moment.
Funds for a Langham upgrade were not likely to be available before 2026 and the process involves
the Asset management Programme (AMP). The bill payer’s contribution and the financial model
need to be vetted by OFWAT and agreement given. It was understood that no work was being done
on this by AW at that point in time. The cost for this (whole life treatment over 35 years) could be in
the region of £5-£10million. There may also be a network issue in terms of how the sewage is
delivered to the treatment plant. Not an attractive proposition for AW and any contribution by
developers would need to be a significant sum.
AW has a duty to accept domestic sewage and the issue then becomes compliance with their permit.
They are then at loggerheads with the EA resulting in very difficult meetings. EA are adamant that
developments must not come before improvements in the system. They require a certainty that
the improvement work will be carried out first.
Other ways of dealing with foul water drainage.
It was assumed that Langham has a combined system of foul water and surface water drainage.
When confronted with a foul water capacity issue other solutions are available (Cess pit, Septic tank,
package treatment plant). All of these are non-mains solutions. However the EA have a policy that in
areas where mains sewage is available they will not sanction non-mains sewage solutions. No
capacity now, is not a reason to move to a non-mains solution. Another option would be to put in a
pipeline and pump everything to the Colchester network which has plenty of capacity. Their waste
discharges in the Colne just below the tidal limit. This may well have serious cost implications as well
as land issues in routing the pipeline.
Current Flooding in Langham involving foul water containment.
It was agreed that putting in non-return valves was not an elegant way of addressing this issue as the
water will inevitably escape somewhere if the network cannot deal with the capacity. EA can only
deal with this as part of any permit enforcement discussions. As expected their view was that this
needs to be addressed directly with AW as foul drainage capacity does not come under their remit.
Ground water infiltration
This can be a big problem during heavy rain periods and over time can seriously affect the volumes
of water being treated. Lining of the pipes can stop ground water infiltration into the pipework and
we think this was carried out in School Road.
Location of Ponds on site plans for surface water drainage
It was stated by EA that ponds could only realistically take the run off from the roofs on new houses.
If ponds are being put forward for SuDS there should be a detailed calculation that can be assessed.
Water levels will vary as the base of any pond will be gravel and during the dry months the pond will
just be dried reeds and mud. There could be a benefit to help with any existing surface water issues
but this is not an elegant solution.
Local Plan Policy SS11
The key deliverables stated in the Local Plan SS11 section on Langham it states that development
will be supported which provides:
- Adequate wastewater treatment and sewage infrastructure capacity in the catchment area
- Appropriate SuDS for managing surface water runoff within the overall design and layout of the
site.
It was agreed by all parties that we should insist on a statement of how SS11 can be delivered with
timescales.
5.2 LPC meeting with AW 14 February 2017
Key Points from the meeting:
AW is a statutory consultee on Local Plans and Neighbourhood Plans. They get involved in planning
applications when asked usually with major developments which are 10 or more dwellings.
There are two key areas in the infrastructure.
Sewage Infrastructure - Developers fund connection to the existing network and only fund their
site(s). If there are any existing issues with the infrastructure AW need to resolve and fund this. They
would need to build costs into the Asset management Period 7, 2020-2025.
Water Recycling Centre – AW said there was capacity at Langham for growth but that might mean
that kit on the ground could be improved or alternatively a simple solution. They do not reserve
capacity so look at each request when it comes forward. This could be a bit of a free for all if more
than one site comes forward at the same time. CBC is therefore being asked for a phased
introduction. AW said that the pipe network was the issue for Langham and they were performing
against their permit requirements. This point needed be clarified by AW as the EA were of the
opinion that this was not the case and they were oversubscribed to the tune of 133 homes. LPC
asked whether we could have a joint meeting with AW and the EA. AW thought this may be possible
and said she would check this.
AW is working with the local authority on a phased number of new dwellings (as an example 50
homes per annum was mentioned) for their 5 year cycle. Any increases in prices need to be agreed
with OFWAT if funding is required to expand or maintain their network.
AW is working with the numbers in the preferred options consultation which is 125 new homes.
They work on flow rates for standard homes or B1 businesses which is a different rate. There could
be limited capacity and infrastructure work could be needed. AW engineers look at network capacity
and the Water Recycling Station. The network effectiveness was affected by the pumping station
performance, what we flush and may need washing out.
AW is broken down into;
- Engineering growth and planning
- Environmental team
- Operations growth, field work on planning
- Future growth
The point about developer’s costs for network connection was discussed and could vary if they run
out of network connection points and an offsite connection is required. Developers could also end
up with planning conditions on foul sewage. It was made clear that any new development should not
affect any existing customers.
We discussed SuDs and AW is clear that this was not their responsibility. They try to ensure that
SuDs does not enter their network although they are prepared to adopt sustainable drainage
systems if their standards are met. They agreed to provide us information or access to a website for
information on this issue. LPC thought that this could be the right approach rather that ponds to
take SuDs which is not an elegant solution.
LPC asked about the updated water cycle study and were told this had been updated by a
consultant. It was agreed that we did not know where we are with this information.
We briefly discussed the concept of piping sewage back to Colchester but this would require
modelling and investment and was not an easy thing to do. We also touched on the operations team
fitting non-return valves but this was put down to the network requirements not any capacity
problems with the Water Recycling Centre.
5.3 LPC meeting with EA and AW (on audio conference) at Iceni House Ipswich on 23rd March 2017.
The 420 Dry Weather Flow (DWF) permit figure issued to AW by EA is 420 cubic metres per day.
They can't easily measure DWF any more so they are now using statistical means, which in our view is
causing a lot of confusion.
They have ended up with two sets of flow rates Q80 and Q90
Q80 is used for planning figures
Q90 is used for compliance
Q90 is less than Q80
Taking an example of the Q90 measured flow in 2015. AW is quoting 382 cubic metres per day against a
permit figure of 420. So they are saying they are compliant. 382 cubic metres per day measured in Q80
format would convert to 436 cubic metres per day. So from a planning perspective they are non-
compliant. The much higher figures of Q90 522 cubic metres per day in 2014 are being
defended by high SuDs egress into the network, and a faulty pump reading. Both of these issues have
apparently been addressed by recent work. So AW says the original response to CBC for the Local Plan
was based on old incorrect data. EA still believe that AW is technically breaking their permit but there is
no enforcement. EA still maintain there should be nil growth. One thing is clear; you can understand why
they don't agree.
AW had a new business plan in preparation 2020-2025, there would also be a plan for longer term waste
water issues and strategy that will feed into the business plan.
The Water Cycle Study is undertaken by consultants, the last one was 2010.
EA made a comment after AW left the meeting. As a private company AW is being told they should
accept new customers and should not stand in the way of development.
Actions that came out of the meeting:
1. AW would work with EA for a common view which would be the basis for an updated response to CBC
for the Local Plan. (We agreed with EA after AW left the meeting that LPC would get sight of this for
comment before it was sent forward).
2. AW would check what has been said to Langham developers and in what context or on what basis it
has been said.
3. EA will provide information on quality parameters i.e. bringing down the phosphate limits by 1mg per
litre of water for x new houses being built. EA will cover the impact of up to 10 new homes then up to 50
new homes and finally up to 125 new homes (including impact on flow rates). This can then
indicate what a new DWF permit might look like.
4. AW will check on progress of the latest Water Cycle Study that will feed the Local Plan and will provide
more information before the consultation phase.
5. AW said they would report back on what specific blockages in the network were worked on and
cleared for Langham.
5.4 Joint Positioning Statement on growth at WRC catchments in the Colchester area - September 2017
After significant lobbying by LPC a joint positioning statement was issued by CBC, AW and EA. The
statement set out the current position relating to the capacity of Langham WRC following the
publication of the Colchester Borough Water Cycle Study (WCS) in December 2016.
The conclusions of this document were that planning applications for development connected to
Langham & Dedham WRCs require careful waste water infrastructure and water quality
consideration to ensure that the objectives of the Water Framework Directive are not compromised.
The timing of development will play a crucial part in this, ensuring that developments are not
progressed ahead of improvements in treatment technology capabilities or the identification of
alternative approaches, to ensure the environment is protected. The relevant Local Plan policies for
development at Langham and Boxted include this requirement.
Anglian Water will continue to monitor the quantity and quality of flows from WRCs in the
Colchester area including Langham (East) and Dedham and will take the necessary steps at the
appropriate time in order to accommodate growth within environmental parameters. Further work
needs to be done to consider and identify all the improvements that will need to be implemented to
enable development to proceed. Given the ongoing nature of the work it should be recognised that
improvements may not be delivered during the earliest stage of the plan.
Langham Parish Council August 2019