MM46

Flawed Defra metric 2.0 does not include irreplaceble distinctive habitats ( by definition these are not included as irreplaceable).
There is no recognition Middlewick is an Acid Grassland.
Use of a proxy mangement company to mitigate the acid content of acid grassland should raise concern about leaching of sulphur into the downstream Birch Brook biobank. There is no evidence base for this mitigation and it should be classed as experimental at best. We should not be experimenting with natural biodiversity, or it will not be nature nor diverse.

Flawed Defra metric 2.0 does not include irreplaceble distinctive habitats ( by definition these are not included as irreplaceable).
There is no recognition Middlewick is an Acid Grassland.
Use of a proxy mangement company to mitigate the acid content of acid grassland should raise concern about leaching of sulphur into the downstream Birch Brook biobank. There is no evidence base for this mitigation and it should be classed as experimental at best. We should not be experimenting with natural biodiversity, or it will not be nature nor diverse.

Do not build on it

The Inspector’s modification adds a management company to be set up to look after
the mitigation of the acid grassland in another area for up to 30 years. There is concern by ecologists that the use of sulphur along with any other chemicals to do this will
have an effect on Birch Brook and the wildlife around this area.
There are no guarantees that an irreplaceable habitat such as acid grassland can be
created from scratch.

- The local plan should establish a "proof of concept" approach in that it should demonstrate that acid grassland can be preserved and created before any development to take place.

- The DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats (because it is irreplaceable).
- The local plan is unsounds because does not demonstrate how acid grassland can be preserved or even fostered despite the planned dwelling

- The local plan is unsounds because it should demonstrate that acid grassland can be preserved and created before any further development.

- The DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats (because it is irreplaceable)

Tighten up monitoring up of management company.

Questions. What happens if the 'Management' company folds or fails to act appropriately. Who will it be responsible to?

Leaving Middlewick 'in limbo', pending some future planning battle leaves all the obvious risks to the site from developer-vandalism to neglect, inappropriate management etc., so that the site should really be protected as a rare acid grassland area.

It is illogical to continue accepting Middlewick development as 'sound' in the current plan. In effect, it accepts the proposal to allocate 1000 houses to Middlewick, but then revises CBC planning policy to ensure very high (practically impossible) hurdles to be met by any particular applicant to develop. These modifications to the planning policy show that the case against development is understood, to the extent that it makes no sense for the plan to have been accepted in the first place.

The Council will require the developer to enter into an appropriate legal agreement to secure the long term (minimum 100-year) management and monitoring of retained protected habitats, the biodiversity mitigation, compensation and net gain land, by the nature conservation organisation, including a mechanism for funding and governance that ensures both the nature conservation value and local community interest. The landowner of the mitigation land will need to be party to such an agreement.

Recognition of the ecological complexity and wildlife value of the site, and a requirement to appoint a suitably experienced management organisation to oversee the works, and legal agreement for the long-term management and monitoring are welcomed.
However, a management and monitoring period of 30 years cannot be described as 'long-term' in ecological terms; the compensatory habitats will barely be established within this time frame and will need much longer to mature into adequate substitutes for those lost; these include semi-natural grasslands that have been in place since the Crimean war, approximately 165 years.

Minimum term for protecting habitats should be in the order of 100+ years as these ancient grasslands take time which is not on the human timescale to develop. You cannot simply “mitigate” effects of habitat destruction by transplanting bits of it elsewhere like they were spring bulbs.

The Defra Metric does not allow for irreplaceable habitats simply because they are not like tulip bulbs which can be dug up and moved elsewhere to flower next spring, the acid grassland recognised in the Middlewick site has taken hundreds of years to develop.

As previous entries, keep the land as near as possible as it is and any development should be the benefit of the population to enjoy the land in a low key manner. The land is to be kept as under developed as possible for now and the generations to come.

The land because of its history is an irreplaceable distinctive habitat.

To try and replicate this by the mitigation of the acid grassland in other area is experimental and there is no evidence that this would work, nature is better at creating than man. Or even a management company working to a 30 year contract.

Use of Sulphur with other chemicals will have an effect on the Birch Brook and wildlife around the area.

There are no positives from this modification, it is needed because of the illogical development of this land

Middlewick Ranges to be reatined as green open space.

The DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats (because it is
irreplaceable).
• The local plan is unsounds because it has not been recognised that this site is acid
grassland.
• The Inspector’s modification adds a management company to look after
the mitigation of the acid grassland in another area for up to 30 years. There is concern by ecologists that the use of sulphur along with any other chemicals to do this will effect Birch Brook and wiildlife.
• There are no guarantees that an irreplaceable habitat such as acid grassland can be
created from scratch.
• There is little evidence that this kind of mitigation will work and is experimental
The management company may fold or pull out or the mitigation fails,
this has not been mentioned.
• The concern of pesticides to kill off competing vegetation to create the acid grassland
could contaminate Birch Brook and surrounding habitat, soil and wildlife.

That no development takes place until Defra has produced its guidances for the new matrix for developments and the environmental bill has been ratified. How can you put in modifcations in based on future uncertain legislation likely to change? This is not fair and transparent.

DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats (because it is
irreplaceable) and any updates and guidance with a new matrix will not be available until late 2022/23. The bespoke metric put forward by Stantec cannot be quantified. This is based on the proposed Environmental bill which is currently under review and will not be ratified for a while yet. Middlewick is caught between future legislation coming out and what is in place now - iti should not be part of any new legislation which is not certain.

The Middlewick Ranges should be turned into a nature reserve.

The local plan doesn't recognise the fact that Middlewick Ranges are a rare habitat that should be protcted (acid grassland) and therefore the plan is unsound. It is not certain whether it will be possible to recreate a habitat of this importance and complexity.

The Middlewick Ranges hould be turned into a nature reserve.

The Middlewick Ranges is recognised as Local Wildlife Site and should have never been included in the plan. Moreover, being a lowland acid grassland, it is a top priority for conversation in the UK and should be protected. The local plan will destroy this delicate and important habitat, along with protected species on it.

I am submitting my objection to the building of houses on Middlewick.
MM35 - Housing Allocation.
As I look around Colchester after living in the town for 74 years, I am concerned with the amount of building that has been going up over the past ten years. I know there is an allocation specified for Colchester to build, but you have gone beyond these figures. The amount of houses alone at Stanway and Severalls old grounds must cover these figures for years to come, they are not needed on Middlewick.
MM36 - Traffic and Transport.
How another 1000 houses with at least two cars per home is going to impact on the roads is beyond me. The only two roads into Colchester are Mersea Road and Old Heath Road. At the time of submitting this there is congestion every day on these roads, there is no other way into town from Mersea and Fingringhoe, Abbot’s Road only leads to these two roads, if trying to get to the Hythe there are traffic jams trying to get to Whitehall Road, where if the roads aren’t flooded the traffic is horrendous, this is not good for the environment at all, surely you must see this.
MM37 - Biodiversity and Wildlife.
Middlewick is full of the most beautiful wildlife you could want and that the world needs to keep, to many species are being lost to the destruction of open spaces, the deers foxes badgers running free is a wonderful thing and you want to destroy all this for 1000 houses, once you have dug this up it will never be replaced, the beautiful grasses for the butterflies the trees for nightingale which are so rare, the planet needs plants and wildlife to survive and the way we are going these are going to disappear.
MM38 - Environmental.
The pollution that will be thrown out by more cars on these road will be devastating. The fumes from the cars and busses will cause major problems to people already suffering from bronchial illnesses. Overpopulation is a big problem, Colchester is a small town, there are so many building going up we will be gridlocked, as soon as there is a problem on the A12 the whole town comes to a standstill, the roads are too small coming into town from this area. We are having trouble already with the sewage, it is unable to cope with more buildings, where is the waste going, we just haven’t got the resources. Children soon won’t have any open spaces left to enjoy, this must stop.
MM40 - Landscape.
This is the most beautiful piece of land left in this once beautiful town. The peace it gives people to just walk and enjoy the wildlife around them. The space to be able to breath fresh air, to see wildlife and hear the birds, after the most terrible last eighteen months, this was a place to go to escape the horror to have a little piece of mind, you cannot destroy this, the beautiful trees that have been growing for hundreds of years, these will never be replaced, please reconsider.
MM45 - Biodiversity Net Gain.
I cannot for one second imagine how you would leave this beautiful piece of countryside in a measurable better state than it was beforehand. How can you even think of being able to substitute the beautiful trees grasses with replacement twigs which would take hundred of years to grow. You would be covering the place with concrete. There is nothing you can do to improve this only destroy everything.
MM46 - Long Term Management and Mitigating.
I understand that there has to be five years of monitoring the habitat before any plan is to be considered, if after five years of monitoring of growth and development of the habitat then the project is discussed, I would ask has this been done, you can’t just decide to build without a independent source. This cannot be pushed under the carpet.
MM47 - Scope
I would ask have up to date surveys been taken? as I understand outdated ones are being used, these are not sound and a independent one is urgently needed.
I would like my objection to be put forward with all the others, and please reconsider this terrible planning.

State that the partner agency will be independently appointed.

Will your environmental partner be one that writes a report favouring building or one that completely disagrees with the development and who’s report you seem to have ignored? Clearly this is a good step but it’s a bit like closing the stable door after the horse has bolted.
The only way to mitigate all the environmental concerns is not to build these homes. Please return the land to the people of Colchester as a beautiful open space to be used by people and the natural world in unison. Use this opportunity to create a legacy, your legacy; to create something sustainable and long lasting from which the people of Colchester and beyond can benefit. Use your imagination to see what could become of this tract of land. You know it makes sense.

The plan needs to be amended to remove development of an irreplaceable distinctive habitat

The plan does not recognise that the site is an irreplaceable distinctive habitat. The Inspector’s modification adds a company to look after the mitigation of the acid grassland in another area for up to 30 years. What happens if this is not maintained or the company folds? Concerns that the use of sulphur and pesticides will affect other areas of wildlife such as Birch Brook. No guarantees that mitigation will be effective, what then? This has not been mentioned in the plan. Mitigation work should be done first, before the ‘irreplaceable distinctive habitats’ are destroyed.

MM38
This build will seriously damage the only green lung in this area to the detriment of the Residents on three sides of the Ranges. There will be nowhere close enough to enjoy nature, breathe clean air, for children to play safe from traffic, to walk dogs, without resorting to the car to go further afield to other open spaces. The wildlife will either leave due to the destruction of their habitats, or they will die off. Middlewick Ranges are adjacent to an SSSI, and site noise and upheaval will be detrimental to the SSSI.
MM35
Air pollution in Colchester is already above Governmental safety guidelines, and especially so on Mersea/Abbott’s Road. Colchester is one of the most polluted towns in the country, and one of the most built up too. There is not the infrastructure to cope. In the last five years 25,628 people have moved into the Colchester area. In the last decade or so seven hospitals have been sold off to housing developers. Severalls,
Essex County, St. Mary’s, Myland, Heath, Essex Hall and the Maternity Hospital. We now have ONE, Colchester General which is frequently overwhelmed, as are GPS, Dentists, schools.
MM36
Traffic congestion is a big problem without more vehicles adding to it, plus ten or more years of dust, dirt, and noise from heavy plant machinery polluting the air further. Entering and exiting the site will cause major congestion and disruption on Abbots/Mersea Road and surrounding roads. In the rush hours it can take over an hour or more to get to work across town to the hospital and other employment, and congestion is ever present where development is ongoing now.
MM37
Middlewick Ranges is a Designated Wildlife Site and contains very rare acid grass which is vital for the survival of certain invertebrates and flora, many of whom are protected species. This lowland acid grass and Heath have remained undisturbed for hundreds of years. There needs to be another up-to-date Ecology Report. The plants and wildlife there will not survive the loss of their habitat. To create acid grass will take many years, may not be successful and the wildlife will die off
MM40
We need to get the Middlewick Ranges reclassified to incorporate the acid grass as it is not all just ‘farmland.’ Many will not want to live within the vicinity of the electricity pylons, either from fear of their effect close up or because they are an eyesore.
MM45
Middlewick Ranges are referred to as ‘a farmland plateau. It is acid grass/Heath.
MM46
It will be impossible to mitigate the upheaval/damage to the habitats of the wildlife. Why was so little made of the fact the Middlewick Ranges are a Local Wildlife Site with protected species. Will the Skylarks wait any number of years for acid grass to be created? and that is just one example. Where will the wildlife go during the intermediary period? Some will possibly go to the adjacent SSSI but most will die off.
Has the wider effect of chemicals been soundly investigated? What guarantees will there be if the Management Company fails?
MM47
The aims for this site are not achievable. They are not in the interests of the Wildlife or the surrounding residents both from a physical and mental health point of view. There is also the fact that Middlewick Ranges were added to the Local Plan without due process taking place.

No development tobe permitted on this land.

The Local Plan is unsound because it has not been recognised that this site is acid grassland and a UK Biodiversity Action Plan habitat. The Green Infrastructure Strategy 2011 is out-of-date and inaccurate in this respect. Furthermore the DEFRA Metric 2 does not allow for irreplaceable distinctive habitats because they are irreplaceable.

Take the Middlewick Ranges proposals out of the Local Plan.

I'm unconvinced the modifications are a reliable solution to replace the current protected acid grasslands and the management of such a replacement. There's no consideration for solutions should the management organisation cease trading or withdraw from the agreement.

I'm concerned with the unreliability of the plans to replace this grassland. The DEFRA Metric 2.0 doesn't allow for irreplaceable distinctive habitats, as they're irreplaceable. There's also little evidence this kind of mitigation will work as it's experimental. Concerns were also raised by ecologists that the use of sulphur to conduct these plans will impact Birch Brook and wildlife in the area.

The Wick should be removed from the Local Plan completely.

"The DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats (because it is irreplaceable).". I think that sums it up really. The Wick is irreplaceable, full stop. I would like the inspector to provide some proof that creating acid grassland has worked elsewhere. He/she won't be able to, because it's never been done and is impossible.

Remove Middlewick from the Local Plan.

As a Councillor for over 15 years, I have seen management plans collapse, Developers and management companies go bust. Money eventually runs out - 30 years in context of a unique natural landscape is nothing. The most successful are managed by residents as they care for the area they live in but this is difficult in a new development with the constant change that comes with that development. Natural wildlife areas can not be managed - they develop over decades and can not be sliced apart and still have the unique attributes that made them what they are.

See above

The DEFRA Metric 2.0 does not allow for irreplaceable distinctive habitats because they cannot be replaced.

The idea that with the use of chemicals the irreplaceable habitat such as acid grass land can be created is risky, at best. If this is indeed possible, why hasn’t it been done before? This habitat is so rare, if it were this achievable, why hasn’t it already been done?

With the use of chemicals, the surrounding precious habitat and wildlife will be badly affected. Birch Brook is so close and will almost definitely be adversely affected and polluted.

If indeed, this suggestion of creating this rare habitat is achievable, it should be undertaken first and proven before any future plan is undertaken.

This plan seems risky, at best and could kill off surrounding vegetation and contaminate Birch Brook, the soil and wildlife.

We need to protect, recover and restore nature and precious habitats NOT DESTROY them.

CBC has already stated this in the Colchester Declaration.

The developer's ecologist's idea that with the use of chemicals, the irreplaceable habitat such as acid grass land, can be recreated is risky, at best. This habitat is so rare, if it were this achievable, why hasn’t it already been done?
Many independent experts views are required, and noted, not just the vested interest of an individual.

If the developer’s ecologist’s plan is executed, surrounding precious habitat and wildlife will be badly affected. Birch Brook is so close and will almost definitely be polluted.

If, this suggestion of recreating this rare habitat is achievable, it should be trialled first and proven, before any future plan is undertaken.

This plan could kill off surrounding vegetation and contaminate Birch Brook, the soil and wildlife to the overall detriment to the area.

We need to protect, recover and restore nature and precious habitats NOT DESTROY them.

CBC has already stated this in the Colchester Declaration.

The acid grassland and wildlife areas should be left in a natural state, not destroyed

*The acid grassland cannot be replaced in a realistic timescale
* the talks around conservation and protecting our wildlife are nonsensical if developers can chose to destroy habitat and attempt to recreate elsewhere to suit themselves. Money over our children’s futures.
*the trust involved with replacing habitat is immense, a disaster waiting to happen.

Cancel

Concern about use of sulfur affecting birch brook and wildlife.

The plan is unsound. IF the plan is approved, the acid grassland creation should first be undertaken and proven that it works before any master plan is put in place.

DEFRA Metric 2.0 doesn't allow for irreplaceable distinctive habitats (because it is irreplaceable!). There is concern by ecologists that the use of sulphur along with any other chemicals (e.g. pesticides) to recreate the habitat will have an effect on Birch Brook and the wildlife surrounding. There are no guarantees that an irreplaceable habitat such as acid grassland can be created from scratch. There is little evidence that this kind of mitigation will work and therefore is experimental. What happens if the management company folds or pulls out or the mitigation fails, this has not been mentioned.

I would like this part of the plan to be amended to show that it was never a feasible option in the first place. The only reason for this section to exist is because the original should have recommended avoiding development in the first place and it simply compounds the error by desperately seeking a way out of the muddle.

Given that DEFRA does not identify a mitigation strategy for distinctive habitats like acid grassland – the proposed solution is untried and high risk given also that the expert advice is that it is not possible. If, as seems likely the mitigation fails to protect the grassland and/or pollutes the adjacent SSSI, there can be no future compensation – the environment will be lost and the houses built. This whole section appears to have been overlooked by the Inspector which is perilous given the disasters we are experiencing through abusing the environment.

The Middlewick Site allocation should be removed from the Plan.

Reference to monitoring ‘retained’ protected habitats is misleading as the destroyed habitat - unique and rare acid grassland - will first need to be recreated, which is far from guaranteed and also carries associated risk of causing acid contamination.
Any management recruited to oversee re-creation of high priority habitats must be independent of the Developer to avoid conflict of interest. There are serious concerns as to whether this strategy of mitigation is plausible, practical or achievable. The harm of development far outweighs the benefits, particularly when housing numbers have been exceeded. Houses can be built elsewhere – irreplaceable habitat cannot.

Leave it as it is for all to enjoy, including some of the last remaining distinctive wildlife and terrain in Colchester and the wider region.

Not only is it priposed to ruin Middlewick but there is also the likelihood that chemicals and pesticides to try to recreate what we already have will affect Birch Brook. This would be a huge costly experiment that might not work. How can this be justified? This is an IRPLACEABLE distinctive habitat. Leave it as it is for all to enjoy, including some of the last remaining distinctive wildlife and terrain in Colchester and the wider region.

Ensure that the creation of the new grassland has worked before destroying the existing one. A plan should be in place in case the management company folds in the 30 year timeline. Also to ensure that this agreement to continue to monitor is legally bounding, should the company building the housing not exist in 30 years or fail to meet the requirement. The funding and governance for this work needs to be found upfront and protected for this purpose, 30 years is a lot of time in government funding and structure years.

This is a high risk strategy, involving changing existing habitats with the use of chemicals to create an area which is planned to be destroyed. It is experimental, unnecessary and surely costly, when this habitat already exists. As I have said before, if it is acknowledged that this environment is needed then why is it being built on in the first place.