Habitat Regulations Assessment of the Main Modifications to the Colchester Section 2 Local Plan 2017 to 2033

the Roman river area including the SSSI region, and essex wildlife trust nature reserves are not mentioned or considered.
Open land/wildlife corridor leading to the coast is contiguous with the proposed Middlewick developement, making the area even more important for wildlife. Impact on this area has not been considered in the document

Given that MM37 highlights the presence of High Priority Habitat [of national importance] supporting a range of protected species [including Red List Species] and the need for full ecological assessments as part of any planning application, why was this site not included in the Habitat Regulation Assessment? This would have been an opportunity to inform the Planners and potential Developers of the irreplaceable nature of this rare and important habitat. The NPPF 2019 glossary describes irreplaceable habitats as “Habitats which would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their age, uniqueness, species diversity or rarity. They include ancient woodland, ancient and veteran trees, blanket bog, limestone pavement, sand dunes, salt marsh and lowland fen.” This list is confirmed as containing examples only and is not definitive. Lowland Acid Grassland is accepted as falling into this category.
Why was this omission overlooked by the Inspector?

MM37 acknowledges the Middlewick Allocation as a Local Wildlife Site Co122 containing habitats of high biodiversity value including High Priority Acid Grassland Habitat. This document (HRA)fails to identify that if the proposal to build on this site goes ahead then this Local Wildlife Site will be lost which therefore puts this allocation in direct conflict with one of the Plans key Environmental Policy Targets for "Zero percent loss of Local Wildlife Sites; ancient woodland; and priority habitats and species."

The Plan cannot be considered sound if its own policies are in conflict with each other.

See attached for full representation