Full protection with Coastlines retained for economic growth

Mersea Islands biodiversity will be damaged by using the preposed sites

Please Add after "to the satisfaction of the Council" "after consultation with appropriate habitat stakeholders.

on-Ministerial Government Department, the Forestry Commission provide no opinion supporting or objecting to applications. Rather we provide advice on the potential impact that the proposed developments could have on trees and woodland including ancient woodland.

We have assessed the allocated sites and have concerns regarding those that are directly adjacent to ancient woodland.

Ancient Woodland:

Ancient woodlands are an irreplaceable habitat. They have great value because they have a long history of woodland cover, being continuously wooded since at least 1600AD with many features remaining undisturbed. This applies equally to Ancient Semi Natural Woodland (ASNW) and Plantations on Ancient Woodland Sites (PAWS).

Paragraph 193 (c) of the National Planning Policy Framework (Dec 2024), states:

"Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists"

It goes on to include what could be considered as "wholly exceptional reasons" and states:

"For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat."

Protecting and expanding England's forests and woodlands, and increasing their value to society and the environment. www.gov.uk/forestrycommissionForestry Commission

As Ancient woodland, ancient trees and veteran trees are irreplaceable, proposed compensation measures should not be considered as part of your assessment of the merits of a development site proposal.

We also particularly refer you to further technical information set out in Natural England and Forestry Commission's Standing Advice on Ancient Woodland - plus supporting Assessment Guide and "Keepers of Time" - Ancient and Native Woodland and Trees Policy in England.

The Standing Advice states that proposals should have a buffer zone of at least 15m from the boundary of ancient woodlands to avoid root damage which can result in loss or deterioration of the woodland. Where assessment shows impacts are likely to extend beyond this distance, you're likely to need a larger buffer zone.

Which is in line with your policy EN4, regarding a minimum 15m buffer. However the Standing Advice and the recommended buffer zones are currently under review and are likely to be updated recommending that the minimum buffer requirement will be increased. While a 15m buffer may be appropriate for a single dwelling, for large scale developments, we would recommend this is increased to 30-50m depending on circumstances. Development that encloses a woodland and removes functional habitat links should be avoided.

The Joint NE/FC Standing Advice also states that both the direct and indirect effects of development should be considered for both the construction and operational phases of any proposed development.

Not just including the potential for actual construction to impact on soils, trees and tree roots. But also the potential for effects when residential developments are in use and result in a likely increase in visitor numbers.

Other impacts to the ancient woodland, for example reducing the resilience of the woodland and making it more vulnerable to change. Increasing the amount of dust, light, air and soil pollution and increasing disturbance to wildlife, also trampling of plants, erosion of soil and noise from additional people, traffic and domestic pets.

Due to the irreplaceable nature of ancient woodland, most temporary effects will result in irreplaceable damage.

It is also worth noting that the Town and Country Planning (Consultation) (England) Direction 2024 mandates that Local Planning Authorities notify the Secretary of State if they are minded to approve any planning applications that could lead to the loss or deterioration of ancient woodland.

Page 2Forestry Commission

Proposed sites adjacent to Ancient Woodland:

Tendring Colchester Borders Garden Community - 3000 houses. 2 ASNW in the area. PP9 North East Colchester - 2000 houses; site abuts SSSI ASNW

PP7 Land off Baker's Lane, West Bergholt - 100 houses; this site abuts and includes ASNW within the site.

PP32 Land North of Halstead Road, West of Fiddlers Wood Eight Ash Green - 250 houses abuts ASNW

PP42 Land at White Hart Lane, West Bergholt - 50 houses, on the site of orchard - Should also be checked to see if land is mentioned as an LNRS priority.

All sites should also be checked against the LNRS ACiB map to check whether any expansion or connection measures are mapped to them.

Policies:

We note policies EN4 and GN4 for Ancient Woodlands and Tree Canopy Cover, as good examples including canopy cover targets and maintenance of new trees.

The Forestry Commission is also promoting the use of home grown timber used in construction as a sustainable building material, therefore reducing the embodied carbon emissions of new builds. In line with the Government's 25 Environment Plan (Page 47), the "Timber in construction" roadmap and the Net Zero Strategy.

Potential use of timber in development could be suggested as an addition to Policy NZ2. If you require any further information, please do not hesitate to contact me. Particularly in relation to effective consideration of woodland, avoidance of ancient woodland, or mitigation and enhancement measures for other woodlands affected by development.

The buffer zone of 15m is inadequate and not in line with Woodland Trust 50m recommendations. 15m buffer would have a significant and negative effect on biodiversity notably the population of nesting nightingales.

Comments as follows:
1. Positive to see the Roman River Corridor inclusion, and to see the high value Colne Valley landscapes recognised in the Landscape Character Assessment.
2. Positive to see mobility hubs and increased attempts at providing for sustainable transport.
3. Concern that the Brownfield Land Register remains very limited and focuses almost entirely on the urban area of Colchester. More should be done to proactively identify brownfield sites across the entire city boundary.
4. Concern that affordable housing delivery has only been 16% per annum on average for the past eight years and that the viability appraisals that accompany this plan must be rigrously tested to ensure that they are robust.
5. Concern that the strategy for Eight Ash Green results in car-dependent ribbon development along the 1124. Site PP32 should not be allocated. It represents unacceptable encroachment into the countryside.
6. Further concern that PP32 conflicts with the previous and latest Colchester Landscape Character Assesssments which seek to protect the Colne Valley. The site will be highly visible from Fordham and Chappel and cannot be screened. See attached by way of example. PP32 should not be allocated.
7. Allocation of Marks Tey North. All housing should be concentrated to the south of the site, in a high density development. Much of the Roman River must be kept inaccessible from residents and their dogs to ensure nature can flourish in the Nature Recovery area. The development must be safely connected to Marks Tey station by pedestrian and bike paths that do not use the polluted A120.
8. There should be minimum density requirements for all sites, not just urban ones.
9. The policy wording for conversions should change from 'only supported' to 'strongly supported.
10. There would be a policy to strongly support the bringing back of empty homes into use. An additional SA Monitoring indicator is required for number of homes brought back into use.

Irreplaceable habitats should remain.

Including the Preferred Options Local Plan Consultation Draft and Policies Map
The Woodland Trust welcomes the opportunity to comment on the Colchester Local Plan Preferred Options. As the UK’s leading woodland conservation charity, our mission is to protect and restore ancient woodland, increase native tree cover, and ensure that planning policy contributes meaningfully to nature recovery, climate resilience, and healthier places for people.
We commend Colchester City Council for producing a Local Plan that places strong emphasis on the environment, green networks, and biodiversity, and for aligning the Plan with the ambitions of the Environment Act 2021 and the Essex Local Nature Recovery Strategy (LNRS). However, we consider that several aspects of the Plan require strengthening to ensure it is sound, consistent with national policy, and capable of effective delivery.
This response sets out our strategic comments on the Plan as a whole, followed by specific objections to Policy PP29 – Land East of School Road, Copford, as shown on the Preferred Options Policies Map.
________________________________________
1. Vision and Strategic Approach
We support the overarching vision of the Plan to address the climate and ecological emergencies, enhance green networks, and embed health and wellbeing throughout plan-making. The recognition that Colchester is one of the most nature-depleted parts of the country, and that nature recovery must be central to future growth, is welcome.
However, the effectiveness of this vision depends on policy consistency and implementation, particularly where growth pressures intersect with irreplaceable habitats. Allocations that undermine ancient woodland protection risk weakening the Plan’s environmental credibility and internal coherence.
________________________________________
2. Strategic Policy ST2 – Environment and the Green Network and Waterways
Policy ST2 sets a strong strategic framework for nature recovery, ecological connectivity, and delivery of the Essex LNRS. We strongly support:
• The identification of strategic biodiversity areas
• The emphasis on habitat connectivity and multifunctional green infrastructure
• The requirement for Green Network and Waterways Plans for major development
However, we are concerned that Policy PP29 directly conflicts with the intent of ST2, by allocating development in immediate proximity to an Ancient Semi-Natural Woodland (ASNW) that forms part of the wider ecological network. Development of the scale proposed risks fragmenting, rather than strengthening, the biodiversity network, contrary to the stated objectives of the Plan.
________________________________________
3. Policy EN4 – Irreplaceable Habitats
We strongly support the inclusion of a dedicated policy on irreplaceable habitats and the recognition of ancient woodland as such. However, for the Plan to be sound, policy wording and allocations must align.
National policy is clear that:
Development resulting in the loss or deterioration of irreplaceable habitats, such as ancient woodland, should be refused unless there are wholly exceptional reasons.
We emphasise that deterioration includes indirect and cumulative impacts, not solely direct land take. Allocations that place high-density residential development adjacent to ancient woodland must therefore be scrutinised against this test at plan-making stage, not deferred to development management.
________________________________________
4. Policy EN5 – New and Existing Trees & Policy GN4 – Tree Canopy Cover
We welcome the Council’s ambition to increase tree canopy cover and protect existing trees. However, ancient woodland is not simply a collection of trees; it is a complex, irreplaceable ecosystem dependent on long-term stability of soils, microclimate, and hydrology.
Tree planting, canopy targets, or Biodiversity Net Gain cannot compensate for harm to ancient woodland, and policies should make this explicit to avoid misinterpretation at application stage.
________________________________________
5. Biodiversity Net Gain and Nature Recovery
We support Policy EN2 and the ambition to deliver Biodiversity Net Gain. However, we reiterate that:
• Ancient woodland and its buffer zones must be excluded from BNG calculations
• BNG must not be relied upon to justify allocations that cause deterioration of irreplaceable habitats
This is particularly relevant to Policy PP29.
________________________________________
6. Place Policy PP29 – Land East of School Road, Copford
Formal Objection
The Woodland Trust objects to Policy PP29 as currently drafted and shown on the Preferred Options Policies Map.
a) Impact on Pits Wood ASNW and Local Wildlife Site
Pits Wood is an Ancient Semi-Natural Woodland and a Local Wildlife Site, and therefore an irreplaceable habitat of the highest sensitivity. The allocation of approximately 300 dwellings immediately adjacent to its southern and eastern boundaries presents a clear risk of deterioration, including:
• Increased recreational pressure from an estimated 700 new residents
• Trampling, soil compaction, and damage to ancient woodland indicator species such as bluebell and wood anemone
• Light, noise, and air pollution
• Domestic pet disturbance
• Increased risk of invasive non-native species
• Long-term degradation of woodland soils and edge habitat
These impacts are well-evidenced, predictable, and difficult to mitigate once established.
________________________________________
b) Inadequate Buffering
While Policy PP29 acknowledges the need for buffering, it fails to secure a defined, policy-compliant buffer of sufficient width. Best practice, supported by the Woodland Trust, indicates:
• A minimum 50 metre buffer between ancient woodland and development
• Larger buffers (up to 100 metres) where development is of significant scale or intensity
Given the scale of this allocation, we do not consider that the policy provides sufficient certainty that unacceptable edge effects can be avoided.
________________________________________
c) Conflict with Strategic Biodiversity Priorities
National datasets identify this area as forming part of the Woodland Priority Habitat Network (England) with High Spatial Priority. Such areas are intended to:
• Buffer and expand existing woodland
• Improve habitat connectivity
• Deliver nature recovery at scale
Allocating high-density housing in this location fundamentally conflicts with these objectives and undermines the Plan’s alignment with the Essex LNRS and Policy ST2.
________________________________________
d) Soundness Concerns
In its current form, Policy PP29 raises concerns in relation to the tests of soundness, in particular:
• Positively Prepared – by failing to avoid foreseeable harm to irreplaceable habitats
• Justified – by selecting a site with clear environmental constraints where less sensitive alternatives may exist
• Consistent with National Policy – given the NPPF’s strong protection for ancient woodland
________________________________________
7. Recommendations
To address these issues, the Woodland Trust recommends that the Council:
1. Removes or significantly revises Policy PP29 to avoid development that would result in deterioration of Pits Wood ASNW; or
2. Substantially reduces the scale of development and secures:
o A minimum 50–100 metre semi-natural buffer, excluded from private gardens
o Explicit policy wording reflecting NPPF protections for irreplaceable habitats
o Long-term management and monitoring arrangements in perpetuity
Without these changes, we consider that Policy PP29 risks causing irreversible harm and undermining the environmental integrity of the Local Plan.
________________________________________
8. Conclusion
The Woodland Trust supports Colchester City Council’s ambition to deliver a Local Plan that responds to the climate and ecological emergencies. However, this ambition must be reflected consistently across both strategic policies and site allocations.
Ancient woodland is irreplaceable. Once degraded, it cannot be recreated elsewhere. The precautionary principle must therefore apply at plan-making stage.
We would welcome ongoing engagement with the Council to help identify alternative approaches that meet housing needs while safeguarding Colchester’s most valuable natural assets.

At "to the satisfaction of the Council" please add "after consultation with appropriate habitat stakeholders"
A problem exists with BNG in that it can be misused if there is not a full survey of existing biodiversity and clear evidence that biodiversity loss can be effectively replaced on that site or a locally available one. Species may depend on specific habitats and replacement habitat may not be immediate or available in close proximity, consequently the species will be lost. Sensitive sites should be subject to comprehensive twelve month (at least), independent ecological examination followed by an effective species protection plan.

At "to the satisfaction of the Council" add "after consultation with appropriate habitat stakeholders".
A problem exists with BNG in that it can be misused if there is no full survey of existing biodiversity on a site, and clear evidence that biodiversity loss can be effectively replaced on that site or a locally available one. Species depend on specific habitats and habitat replacement may not immediate or available in close proximity, consequently the species will be lost. Sensitive sites should be subject to comprehensive, twelve months (at least), independent ecological examination followed by an effective species protection plan.

West Bergholt Parish Council supports this policy.

While I support everything within the Policy you as the Council have totally ignored it by allocating PP9 into the Local Plan. You know that any proposal will have an adverse effect on Bullock Wood SSSI, there is no way you can argue otherwise, and there are no "exceptional reasons" to allow this, therefore you breach your own Policy and National guidelines, e.g. NPPF (Dec 2024) section 193 (c) (You list this as section 186 (c), so you must be referencing a different version) and the Government document "Ancient woodland, ancient trees and veteran trees: advice for making planning decisions" which says the same thing . Residential building cannot be an exceptional reason, because otherwise this limitation would meaningless. Do you agree?

Essex Wildlife Trust welcomes the opportunity to respond to the Colchester Local Plan Preferred Options
(Regulation 18) consultation. Our response focuses on the environmental policies within the draft Plan, assessed
against current legislative requirements and national policy, including the Environment Act 2021, the National
Planning Policy Framework (December 2024) (NPPF), the Conservation of Habitats and Species Regulations 2017
(the Habitats Regulations), the Wildlife and Countryside Act 1981 (as amended), the NERC Act 2006 and the
Essex Local Nature Recovery Strategy (Essex LNRS).
1. Overall Assessment
Overall, the draft Plan provides a good framework for protecting and enhancing Colchester’s natural environment.
The policies align with statutory requirements under the Environment Act 2021, the Habitats Regulations, the
Wildlife and Countryside Act and the NERC Act 2006. The integration of the Essex LNRS throughout the policies is
welcome and provides a mechanism for coordinating nature recovery efforts at the local level.
Policy EN1 on Nature Conservation Designated Sites provides robust protection for internationally and nationally
designated sites, with clear provisions for the Essex Coast Recreational disturbance Avoidance and Mitigation
Strategy (RAMS). Policy EN3 on Biodiversity and Geodiversity is comprehensive in scope, covering designated
sites, protected species, Priority Habitats and Species, and habitats of local importance, and the policies relating
to the Green Network and Waterways establish a strategic framework for multifunctional green infrastructure.
However, our assessment has identified one key strategic omission and several areas where policies could be
strengthened to align fully with the most recent national policy updates and government biodiversity
commitments. These are set out in detail below.
2. Key Strategic Omission: The 30x30 Target
The most significant gap we have identified is the absence of any reference to the UK Government’s commitment
to protect 30% of land for nature by 2030, known as the 30x30 target. This is a critical strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage.
2
At the UN Biodiversity Summit COP15 in December 2022, the UK Government formally committed to protecting
and conserving a minimum of 30% of land and sea for biodiversity by 2030. This commitment was reinforced
domestically, with Defra publishing delivery criteria and a map in December 2023 setting out what should count
towards the 30x30 target in England. The target has been further emphasised through the UK’s National
Biodiversity Strategy and Action Plan published in February 2025, which outlines how the UK will meet all 23
Global Biodiversity Framework targets, including 30x30.
The 30x30 target is not merely aspirational; it is a central pillar of the UK’s biodiversity strategy and a key driver for
reversing nature decline. Local Plans have an important role in contributing to this national commitment by
identifying how growth and development will support, rather than undermine, the expansion and improvement of
protected areas and other effective area-based conservation measures.
The draft Plan identifies “strategic biodiversity areas” which present the best opportunities for habitat creation and
enhancement. Policy GN2 provides explicit support for delivering the Essex LNRS and identifies the Roman River
corridor as a nature recovery area. Policy EN2 identifies four strategic offsite Biodiversity Net Gain sites. These
policies directly support nature recovery objectives but make no reference to how this contributes to the 30x30
target.
Recommendation: We recommend that explicit reference to the 30x30 target is incorporated into Policy ST2
(Environment and the Green Network and Waterways), Policy GN2 (Strategic Green Spaces and Nature Recovery),
and Policy EN2 (Biodiversity Net Gain and Environmental Net Gain). This would demonstrate how the Local Plan
contributes to this important national commitment and provide a clear strategic context for the delivery of nature’s
recovery in Colchester.
3. National Planning Policy Framework December 2024 Updates
The National Planning Policy Framework was updated in December 2024 and includes specific new requirements
that should be reflected in the Plan. Paragraph 187(d) now explicitly requires planning policies and decisions to
minimise impacts on biodiversity and provide net gains, “including by establishing coherent ecological networks
that are more resilient to current and future pressures and incorporating features which support priority or
threatened species such as swifts, bats and hedgehogs.”
While the draft Plan includes comprehensive biodiversity policies, the specific reference to swifts, bats, and
hedgehogs in national policy should be explicitly reflected in local policies. These species face particular threats
from development, and incorporating specific features to support them (such as swift bricks, bat boxes, and
hedgehog highways) represents best practice in biodiversity enhancement.
Recommendation: We recommend that Policy EN3 (Biodiversity and Geodiversity), Policy ST8 (Place Shaping
Principles), and Policy GN1 (Open Space and Green Network and Waterways Principles) are updated to explicitly
reference the requirement to incorporate features supporting priority and threatened species, with particular
attention to swifts, bats, and hedgehogs as identified in national policy.
4. Policy EN2: Biodiversity Net Gain and Ambition
Policy EN2 correctly acknowledges that Biodiversity Net Gain is now a mandatory statutory requirement under the
Environment Act 2021, with development required to deliver a minimum of 10% BNG. The policy appropriately
focuses on maximising onsite delivery and identifies four strategic offsite BNG sites with high strategic significance
for biodiversity. This approach is sound and well-justified.
However, we note that the policy focuses on delivering the statutory 10% minimum without exploring whether a
higher percentage of BNG would be required to achieve the strategic habitat creation objectives set out in the
Essex LNRS. The Essex LNRS aims to significantly increase habitat coverage across the county. There is a
question as to whether the cumulative delivery of multiple development schemes each achieving 10% BNG will be
sufficient to meet these more ambitious habitat creation targets, or whether higher BNG percentages should be
encouraged in strategic locations.
3
We recognise that BNG requirements are delivered through separate statutory mechanisms and do not need to be
repeated in planning policy. However, the Plan could be strengthened by encouraging developers to explore
opportunities for higher percentages of BNG delivery where this would support delivery of Essex LNRS habitat
creation priorities and contribute to nature recovery objectives.
Recommendation: We recommend that Policy EN2 is revised to clarify the relationship between statutory BNG
requirements and the Plan’s strategic approach to BNG delivery, and to encourage BNG delivery beyond the
statutory minimum where this would support Essex LNRS priorities. We also recommend that the policy includes
reference to how strategic BNG delivery contributes to the 30x30 target.
5. Climate Change Adaptation
The NPPF December 2024 includes updated provisions on climate change, with paragraph 163 requiring planning
applications to address the “full range of potential climate change impacts.” The draft Plan includes references to
climate change throughout the environmental policies, and Policy EN8 on Flood Risk and Sustainable Drainage
Systems provides comprehensive provisions for climate adaptation in the context of water management.
However, the integration of climate adaptation measures into biodiversity and habitat creation policies could be
strengthened. Climate change is placing increasing pressure on habitats and species, and nature recovery efforts
must consider long-term resilience to changing climatic conditions. This includes consideration of climateappropriate species selection, habitat design that anticipates future climate conditions, and measures to enhance
the climate resilience of designated sites and their supporting habitats.
Recommendation: We recommend that climate adaptation provisions are strengthened across the
environmental policies, with particular attention to Policy EN3 (Biodiversity and Geodiversity), Policy EN4
(Irreplaceable Habitats), and Policy EN5 (New and Existing Trees). This should include requirements for climateadapted habitat creation and species selection that considers future climate projections.
6. Specific Policy Comments
Policy EN1: Nature Conservation Designated Sites
This policy provides robust protection for designated sites and complies with the Habitats Regulations. The
integration of the Essex Coast RAMS is comprehensive, and the innovative provisions for nature-based welcome
packs for large developments are welcomed.
Policy EN3: Biodiversity and Geodiversity
This is a comprehensive policy covering a range of biodiversity interests including designated sites, protected
species, Priority Habitats and Species, and habitats of local importance. The policy properly requires application
of the mitigation hierarchy and includes provisions for Local Wildlife Site buffering. The reference to the “creating
space for nature” design principles in the Biodiversity Supplementary Planning Document is helpful, although the
Council should ensure that the SPD is adopted in a timely manner or that the policy provides sufficient standalone
guidance if the SPD is delayed.
Policy EN4: Irreplaceable Habitats
This policy provides protection for irreplaceable habitats in compliance with the Biodiversity Gain Requirements
(Irreplaceable Habitat) Regulations 2024 and NPPF paragraph 186(c). However, the policy’s approach to buffer
zones requires strengthening. While the policy correctly identifies a 15-metre buffer zone for ancient woodland
and acknowledges that larger buffer zones may be required where surveys show impacts extending beyond this
distance, Natural England guidance is clear that 15 metres represents the minimum requirement for a root
protection zone only. Buffers may need to be significantly increased depending on multiple factors including
development type, the nature and extent of impacts, and the particular sensitivities of protected species
associated with the woodland.
Ancient woodlands support specialist and sensitive wildlife that can be affected by development impacts well
beyond the 15-metre root protection zone. These impacts include noise disturbance, light pollution, domestic pet
4
predation (particularly from cats), recreational pressure from residents, and edge effects such as increased wind
exposure and changes to microclimate. For example, ground-nesting birds such as nightingales require buffers
sufficient to protect them from disturbance, while bat populations may be affected by artificial lighting many tens
of metres from woodland edges. Buffer zones must therefore be designed to address the full range of potential
impacts on both the habitat itself and the species it supports, not merely to protect tree roots.
Recommendation: We recommend that the policy is strengthened to make clear that 15 metres is the minimum
buffer for root protection only, and that significantly larger buffers will be required to address the full range of
potential impacts including noise, light pollution, recreational pressure, and disturbance to protected species. The
policy should require applicants to assess all potential impacts and design buffer zones accordingly, with clear
justification required where buffer widths are proposed. Additionally, the justification text would benefit from
clarification that loss of irreplaceable habitats requires bespoke compensation in addition to any Biodiversity Net
Gain requirements that apply to the remainder of a development site, and that off-site biodiversity units and
statutory biodiversity credits cannot be used to compensate for the loss of irreplaceable habitat.
Policy EN8: Flood Risk and Sustainable Drainage Systems
This policy provides strong coverage of flood risk management and sustainable drainage, with a welcome
emphasis on nature-based solutions. The requirement for multifunctional SuDS that enhance biodiversity and
provide amenity value is strongly supported. The policy would benefit from explicit clarification that SuDS features
can contribute to Biodiversity Net Gain delivery, and where they do so, they must meet the 30-year habitat
management and monitoring requirements of the BNG regulations.
Policy GN2: Strategic Green Spaces and Nature Recovery
This policy provides strong support for delivering the Essex LNRS and identifies the Roman River corridor as a
specific nature recovery area. This strategic approach to landscape-scale nature recovery is welcome. However,
as noted above, the policy would be significantly strengthened by explicit reference to the 30x30 target and how
strategic green space and nature recovery delivery in Colchester will contribute to this national commitment.
Policy GN4: Tree Canopy Cover
The requirement for a 10% tree canopy cover target for major applications is supported. We note that the
justification text references research concluding that an average tree canopy cover of 20% should be set as the
minimum standard for most UK towns and cities. While we recognise the practical challenges of achieving higher
targets, we encourage the Council to review whether a more ambitious target could be appropriate for Colchester,
particularly given the multiple benefits that trees provide for biodiversity, climate adaptation, air quality, and
human health and wellbeing.
7. Essex Wildlife Trust’s Biodiversity Net Gain Proposals
Essex Wildlife Trust welcomes the identification of our proposals at Abbotts Hall Farm, Great Wigborough as one
of the Council’s preferred strategic offsite BNG sites in Policy EN2. As set out in the policy justification, the
creation of a BNG habitat bank at Abbotts Hall will contribute to the Trust’s wider ambitions to rewild the site and
establish a nature reserve, which will be open to the public in 2026. The site is strategically significant, being
adjacent to the Blackwater Estuary SPA, Ramsar and SSSI and the Essex Estuaries SAC, while also connected to
other coastal nature conservation sites including Old Hall Marshes (RSPB) and Copt Hall (National Trust).
Proposed habitats at Abbotts Hall include lowland mixed deciduous woodland, ponds, medium distinctiveness
scrub, individual trees, species-rich native hedgerow, grassland, ditches, and saltmarsh. There are opportunities
for extensive habitat creation on formerly cultivated fields including grassland, wetland and woodland. Habitat
creation measures will integrate with adjacent and nearby internationally designated sites and will prioritise locally
relevant species including Nightingale and Turtle Dove.
The Trust is committed to working with the Council to deliver high-quality biodiversity net gain through this site,
ensuring that development in Colchester makes a meaningful contribution to nature’s recovery at a landscape
scale.
5
8. Conclusion
The draft Regulation 18 policies generally align with current statutory requirements and overall provide an
acceptable framework for protecting and enhancing the natural environment. The integration of the Essex LNRS
throughout the Plan is particularly welcomed and should provide an effective mechanism for coordinating local
nature recovery efforts with county-wide objectives.
However, the absence of any reference to the UK Government’s 30x30 target represents a strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage. The 30x30 commitment is a central
pillar of the UK’s biodiversity strategy and Local Plans have an important role in demonstrating how growth and
development will support, rather than undermine, the achievement of this national target.
We also recommend that the Plan is updated to explicitly reflect the requirements of the NPPF December 2024,
particularly the specific provisions relating to priority and threatened species such as swifts, bats, and hedgehogs.
Climate adaptation provisions could be strengthened across the environmental policies, and Policy EN2 would
benefit from greater ambition in encouraging BNG delivery beyond the statutory minimum where this would
support Essex LNRS priorities. Policy EN4 requires strengthening to clarify that 15 metres is the minimum buffer
for tree root protection, and that significantly larger buffers around ancient woodlands may be required to address
the full range of potential impacts.
Essex Wildlife Trust looks forward to continuing to work constructively with Colchester City Council as the Local
Plan progresses through the plan-making process. Should you require any clarification on the points raised in this
response, or wish to discuss any aspect of nature conservation and recovery in Colchester, please do not hesitate
to contact us.

Essex Wildlife Trust welcomes the opportunity to respond to the Colchester Local Plan Preferred Options
(Regulation 18) consultation. Our response focuses on the environmental policies within the draft Plan, assessed
against current legislative requirements and national policy, including the Environment Act 2021, the National
Planning Policy Framework (December 2024) (NPPF), the Conservation of Habitats and Species Regulations 2017
(the Habitats Regulations), the Wildlife and Countryside Act 1981 (as amended), the NERC Act 2006 and the
Essex Local Nature Recovery Strategy (Essex LNRS).
1. Overall Assessment
Overall, the draft Plan provides a good framework for protecting and enhancing Colchester’s natural environment.
The policies align with statutory requirements under the Environment Act 2021, the Habitats Regulations, the
Wildlife and Countryside Act and the NERC Act 2006. The integration of the Essex LNRS throughout the policies is
welcome and provides a mechanism for coordinating nature recovery efforts at the local level.
Policy EN1 on Nature Conservation Designated Sites provides robust protection for internationally and nationally
designated sites, with clear provisions for the Essex Coast Recreational disturbance Avoidance and Mitigation
Strategy (RAMS). Policy EN3 on Biodiversity and Geodiversity is comprehensive in scope, covering designated
sites, protected species, Priority Habitats and Species, and habitats of local importance, and the policies relating
to the Green Network and Waterways establish a strategic framework for multifunctional green infrastructure.
However, our assessment has identified one key strategic omission and several areas where policies could be
strengthened to align fully with the most recent national policy updates and government biodiversity
commitments. These are set out in detail below.
2. Key Strategic Omission: The 30x30 Target
The most significant gap we have identified is the absence of any reference to the UK Government’s commitment
to protect 30% of land for nature by 2030, known as the 30x30 target. This is a critical strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage.
2
At the UN Biodiversity Summit COP15 in December 2022, the UK Government formally committed to protecting
and conserving a minimum of 30% of land and sea for biodiversity by 2030. This commitment was reinforced
domestically, with Defra publishing delivery criteria and a map in December 2023 setting out what should count
towards the 30x30 target in England. The target has been further emphasised through the UK’s National
Biodiversity Strategy and Action Plan published in February 2025, which outlines how the UK will meet all 23
Global Biodiversity Framework targets, including 30x30.
The 30x30 target is not merely aspirational; it is a central pillar of the UK’s biodiversity strategy and a key driver for
reversing nature decline. Local Plans have an important role in contributing to this national commitment by
identifying how growth and development will support, rather than undermine, the expansion and improvement of
protected areas and other effective area-based conservation measures.
The draft Plan identifies “strategic biodiversity areas” which present the best opportunities for habitat creation and
enhancement. Policy GN2 provides explicit support for delivering the Essex LNRS and identifies the Roman River
corridor as a nature recovery area. Policy EN2 identifies four strategic offsite Biodiversity Net Gain sites. These
policies directly support nature recovery objectives but make no reference to how this contributes to the 30x30
target.
Recommendation: We recommend that explicit reference to the 30x30 target is incorporated into Policy ST2
(Environment and the Green Network and Waterways), Policy GN2 (Strategic Green Spaces and Nature Recovery),
and Policy EN2 (Biodiversity Net Gain and Environmental Net Gain). This would demonstrate how the Local Plan
contributes to this important national commitment and provide a clear strategic context for the delivery of nature’s
recovery in Colchester.
3. National Planning Policy Framework December 2024 Updates
The National Planning Policy Framework was updated in December 2024 and includes specific new requirements
that should be reflected in the Plan. Paragraph 187(d) now explicitly requires planning policies and decisions to
minimise impacts on biodiversity and provide net gains, “including by establishing coherent ecological networks
that are more resilient to current and future pressures and incorporating features which support priority or
threatened species such as swifts, bats and hedgehogs.”
While the draft Plan includes comprehensive biodiversity policies, the specific reference to swifts, bats, and
hedgehogs in national policy should be explicitly reflected in local policies. These species face particular threats
from development, and incorporating specific features to support them (such as swift bricks, bat boxes, and
hedgehog highways) represents best practice in biodiversity enhancement.
Recommendation: We recommend that Policy EN3 (Biodiversity and Geodiversity), Policy ST8 (Place Shaping
Principles), and Policy GN1 (Open Space and Green Network and Waterways Principles) are updated to explicitly
reference the requirement to incorporate features supporting priority and threatened species, with particular
attention to swifts, bats, and hedgehogs as identified in national policy.
4. Policy EN2: Biodiversity Net Gain and Ambition
Policy EN2 correctly acknowledges that Biodiversity Net Gain is now a mandatory statutory requirement under the
Environment Act 2021, with development required to deliver a minimum of 10% BNG. The policy appropriately
focuses on maximising onsite delivery and identifies four strategic offsite BNG sites with high strategic significance
for biodiversity. This approach is sound and well-justified.
However, we note that the policy focuses on delivering the statutory 10% minimum without exploring whether a
higher percentage of BNG would be required to achieve the strategic habitat creation objectives set out in the
Essex LNRS. The Essex LNRS aims to significantly increase habitat coverage across the county. There is a
question as to whether the cumulative delivery of multiple development schemes each achieving 10% BNG will be
sufficient to meet these more ambitious habitat creation targets, or whether higher BNG percentages should be
encouraged in strategic locations.
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We recognise that BNG requirements are delivered through separate statutory mechanisms and do not need to be
repeated in planning policy. However, the Plan could be strengthened by encouraging developers to explore
opportunities for higher percentages of BNG delivery where this would support delivery of Essex LNRS habitat
creation priorities and contribute to nature recovery objectives.
Recommendation: We recommend that Policy EN2 is revised to clarify the relationship between statutory BNG
requirements and the Plan’s strategic approach to BNG delivery, and to encourage BNG delivery beyond the
statutory minimum where this would support Essex LNRS priorities. We also recommend that the policy includes
reference to how strategic BNG delivery contributes to the 30x30 target.
5. Climate Change Adaptation
The NPPF December 2024 includes updated provisions on climate change, with paragraph 163 requiring planning
applications to address the “full range of potential climate change impacts.” The draft Plan includes references to
climate change throughout the environmental policies, and Policy EN8 on Flood Risk and Sustainable Drainage
Systems provides comprehensive provisions for climate adaptation in the context of water management.
However, the integration of climate adaptation measures into biodiversity and habitat creation policies could be
strengthened. Climate change is placing increasing pressure on habitats and species, and nature recovery efforts
must consider long-term resilience to changing climatic conditions. This includes consideration of climateappropriate species selection, habitat design that anticipates future climate conditions, and measures to enhance
the climate resilience of designated sites and their supporting habitats.
Recommendation: We recommend that climate adaptation provisions are strengthened across the
environmental policies, with particular attention to Policy EN3 (Biodiversity and Geodiversity), Policy EN4
(Irreplaceable Habitats), and Policy EN5 (New and Existing Trees). This should include requirements for climateadapted habitat creation and species selection that considers future climate projections.
6. Specific Policy Comments
Policy EN1: Nature Conservation Designated Sites
This policy provides robust protection for designated sites and complies with the Habitats Regulations. The
integration of the Essex Coast RAMS is comprehensive, and the innovative provisions for nature-based welcome
packs for large developments are welcomed.
Policy EN3: Biodiversity and Geodiversity
This is a comprehensive policy covering a range of biodiversity interests including designated sites, protected
species, Priority Habitats and Species, and habitats of local importance. The policy properly requires application
of the mitigation hierarchy and includes provisions for Local Wildlife Site buffering. The reference to the “creating
space for nature” design principles in the Biodiversity Supplementary Planning Document is helpful, although the
Council should ensure that the SPD is adopted in a timely manner or that the policy provides sufficient standalone
guidance if the SPD is delayed.
Policy EN4: Irreplaceable Habitats
This policy provides protection for irreplaceable habitats in compliance with the Biodiversity Gain Requirements
(Irreplaceable Habitat) Regulations 2024 and NPPF paragraph 186(c). However, the policy’s approach to buffer
zones requires strengthening. While the policy correctly identifies a 15-metre buffer zone for ancient woodland
and acknowledges that larger buffer zones may be required where surveys show impacts extending beyond this
distance, Natural England guidance is clear that 15 metres represents the minimum requirement for a root
protection zone only. Buffers may need to be significantly increased depending on multiple factors including
development type, the nature and extent of impacts, and the particular sensitivities of protected species
associated with the woodland.
Ancient woodlands support specialist and sensitive wildlife that can be affected by development impacts well
beyond the 15-metre root protection zone. These impacts include noise disturbance, light pollution, domestic pet
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predation (particularly from cats), recreational pressure from residents, and edge effects such as increased wind
exposure and changes to microclimate. For example, ground-nesting birds such as nightingales require buffers
sufficient to protect them from disturbance, while bat populations may be affected by artificial lighting many tens
of metres from woodland edges. Buffer zones must therefore be designed to address the full range of potential
impacts on both the habitat itself and the species it supports, not merely to protect tree roots.
Recommendation: We recommend that the policy is strengthened to make clear that 15 metres is the minimum
buffer for root protection only, and that significantly larger buffers will be required to address the full range of
potential impacts including noise, light pollution, recreational pressure, and disturbance to protected species. The
policy should require applicants to assess all potential impacts and design buffer zones accordingly, with clear
justification required where buffer widths are proposed. Additionally, the justification text would benefit from
clarification that loss of irreplaceable habitats requires bespoke compensation in addition to any Biodiversity Net
Gain requirements that apply to the remainder of a development site, and that off-site biodiversity units and
statutory biodiversity credits cannot be used to compensate for the loss of irreplaceable habitat.
Policy EN8: Flood Risk and Sustainable Drainage Systems
This policy provides strong coverage of flood risk management and sustainable drainage, with a welcome
emphasis on nature-based solutions. The requirement for multifunctional SuDS that enhance biodiversity and
provide amenity value is strongly supported. The policy would benefit from explicit clarification that SuDS features
can contribute to Biodiversity Net Gain delivery, and where they do so, they must meet the 30-year habitat
management and monitoring requirements of the BNG regulations.
Policy GN2: Strategic Green Spaces and Nature Recovery
This policy provides strong support for delivering the Essex LNRS and identifies the Roman River corridor as a
specific nature recovery area. This strategic approach to landscape-scale nature recovery is welcome. However,
as noted above, the policy would be significantly strengthened by explicit reference to the 30x30 target and how
strategic green space and nature recovery delivery in Colchester will contribute to this national commitment.
Policy GN4: Tree Canopy Cover
The requirement for a 10% tree canopy cover target for major applications is supported. We note that the
justification text references research concluding that an average tree canopy cover of 20% should be set as the
minimum standard for most UK towns and cities. While we recognise the practical challenges of achieving higher
targets, we encourage the Council to review whether a more ambitious target could be appropriate for Colchester,
particularly given the multiple benefits that trees provide for biodiversity, climate adaptation, air quality, and
human health and wellbeing.
7. Essex Wildlife Trust’s Biodiversity Net Gain Proposals
Essex Wildlife Trust welcomes the identification of our proposals at Abbotts Hall Farm, Great Wigborough as one
of the Council’s preferred strategic offsite BNG sites in Policy EN2. As set out in the policy justification, the
creation of a BNG habitat bank at Abbotts Hall will contribute to the Trust’s wider ambitions to rewild the site and
establish a nature reserve, which will be open to the public in 2026. The site is strategically significant, being
adjacent to the Blackwater Estuary SPA, Ramsar and SSSI and the Essex Estuaries SAC, while also connected to
other coastal nature conservation sites including Old Hall Marshes (RSPB) and Copt Hall (National Trust).
Proposed habitats at Abbotts Hall include lowland mixed deciduous woodland, ponds, medium distinctiveness
scrub, individual trees, species-rich native hedgerow, grassland, ditches, and saltmarsh. There are opportunities
for extensive habitat creation on formerly cultivated fields including grassland, wetland and woodland. Habitat
creation measures will integrate with adjacent and nearby internationally designated sites and will prioritise locally
relevant species including Nightingale and Turtle Dove.
The Trust is committed to working with the Council to deliver high-quality biodiversity net gain through this site,
ensuring that development in Colchester makes a meaningful contribution to nature’s recovery at a landscape
scale.
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8. Conclusion
The draft Regulation 18 policies generally align with current statutory requirements and overall provide an
acceptable framework for protecting and enhancing the natural environment. The integration of the Essex LNRS
throughout the Plan is particularly welcomed and should provide an effective mechanism for coordinating local
nature recovery efforts with county-wide objectives.
However, the absence of any reference to the UK Government’s 30x30 target represents a strategic omission that
should be addressed before the Plan proceeds to the Regulation 19 stage. The 30x30 commitment is a central
pillar of the UK’s biodiversity strategy and Local Plans have an important role in demonstrating how growth and
development will support, rather than undermine, the achievement of this national target.
We also recommend that the Plan is updated to explicitly reflect the requirements of the NPPF December 2024,
particularly the specific provisions relating to priority and threatened species such as swifts, bats, and hedgehogs.
Climate adaptation provisions could be strengthened across the environmental policies, and Policy EN2 would
benefit from greater ambition in encouraging BNG delivery beyond the statutory minimum where this would
support Essex LNRS priorities. Policy EN4 requires strengthening to clarify that 15 metres is the minimum buffer
for tree root protection, and that significantly larger buffers around ancient woodlands may be required to address
the full range of potential impacts.
Essex Wildlife Trust looks forward to continuing to work constructively with Colchester City Council as the Local
Plan progresses through the plan-making process. Should you require any clarification on the points raised in this
response, or wish to discuss any aspect of nature conservation and recovery in Colchester, please do not hesitate
to contact us.

Farmland is irreplaceable. Build upwards in urban areas not outwards over land that should be providing food security for our nation

As the term irreplaceable indicates, these habitats cannot be replaced. While the policy states that the loss of an irreplaceable habitat will not be permitted unless there are wholly exceptional reasons, it also implies that it is possible to compensate for the loss of an irreplaceable habitat. The policy should be clear that this is not possible. Where development is permitted adjacent to an irreplaceable habitat, the potential for impacts leading to degradation of the habitat should also be considered. as well as impacts on connectivity and fragmentation.

Proposed Housing Allocations Affecting Copford with Easthorpe Parish
The Regulation 18 Draft Local Plan proposes two major housing allocations affecting Copford with Easthorpe Parish:
• Policy PP29 – Land east of School Road, Copford: approximately 300 homes
• Policy PP17 – Land behind shops off London Road, Marks Tey: approximately 1,500 homes, crossing the Marks Tey / Copford parish boundary, with an estimated 600 homes located within Copford with Easthorpe Parish
Together, these allocations represent an additional 900 homes within the Parish. Based on an average household size of three people, this equates to an increase of approximately 2,700 residents.
While I recognise the need to identify sites to meet the City-wide housing target of approximately 21,000 new homes, I have serious concerns about where and how these homes are proposed and whether the necessary infrastructure can realistically be delivered. The scale of development proposed for Copford with Easthorpe Parish is neither fair nor proportionate.
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Conflict with the Vision and Objectives of the Local Plan
Section 2 (paragraph 2.19) of the Draft Local Plan sets out a vision of:
• “preserving Colchester’s identity” and
• “improving the quality of life of our residents”.
These are objectives I strongly support. However, the sheer scale of development proposed under PP17 and PP29 will have a significant and overall negative impact on this area. The scale, density and location of the proposed sites do not preserve local identity, rural character or biodiversity, and are therefore inconsistent with the stated vision of the Plan.
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Policy PP29 – Impact on Rural Character and Heritage Assets
The proposed housing density under PP29 would result in a substantial erosion of the rural nature of the Parish.
While the seven Grade II listed buildings and the Copford Green Conservation Area may not be directly affected by the development boundary, they will be adversely impacted by the inevitable increase in traffic, noise and pollution generated by the proposal.
Although the Draft Local Plan refers to a City-wide Housing Needs Survey, it makes no reference to the Copford Local Housing Needs Survey, which should be a material consideration when assessing local housing requirements.
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Policy PP17 – Cross-Boundary Development Concerns
With regard to Policy PP17, it is notable that Colchester City Council has recently refused an application for 175 homes in Tiptree, citing cross-boundary planning issues. Given this precedent, it logically follows that a proposal for 1,500 homes straddling the parishes of Marks Tey and Copford with Easthorpe should be subject to the same concern and scrutiny.
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Infrastructure Constraints
In addition to the scale of development, I have serious concerns about whether essential infrastructure can support these allocations.
Wastewater Treatment and Water Supply
Copford Water Recycling Works has very limited remaining capacity, with only 33% permitted Dry Weather Flow (DWF) capacity remaining (Colchester Water Cycle Study – Interim Findings, February 2025). The study identifies a “high risk of water quality non-compliance”.
While the interim AECOM report suggests sufficient water supply for new development, it does not specify where this additional water will come from. There has been speculation that this will rely heavily on reducing domestic water consumption to below 100 litres per person per day, an assumption that is both uncertain and unrealistic. Furthermore, the report does not account for wastewater and water supply requirements arising from existing allocations, let alone new ones.
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Road Network and Transport Impacts
There are already significant and well-documented problems on both the A12 and A120, with conditions on the A120 widely acknowledged as severe and unsustainable.
Additional housing will place further strain on these routes and will inevitably impact local roads, particularly:
• London Road (B1408), and
• School Road, the likely access route for PP29.
School Road is a major route to and from Copford Primary School, is already heavily congested at peak times, and is increasingly used as a rat run towards the A12 via Easthorpe Road and from Maldon Road via Fountain Lane and Aldercar. It is also used by HGVs.
Traffic generated by PP29 alone could result in up to 600 additional vehicle movements per day, significantly worsening congestion, pollution and road safety risks. This is of particular concern given the large number of children crossing School Road daily to attend the primary school. The proposal is therefore likely to result in an unacceptable impact on highway safety, and it is difficult to see how the policy objective of “safe pedestrian access” can realistically be achieved.
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Active Travel and Public Transport
Policy ST1 – Health and Wellbeing promotes active travel, which is commendable in principle. However, it is difficult to see how increased walking and cycling can be realistically achieved in the context of:
• higher traffic volumes,
• increased congestion, and
• safety concerns along School Road, London Road (B1408) and the A120.
Rather than promoting healthier lifestyles, the development risks leading to:
• increased noise and air pollution,
• compromised air quality, and
• wider environmental harm.
The suggested mitigation of a modal shift towards public transport is also problematic. Public transport options are limited to bus services on London Road, which are infrequent outside peak hours and become increasingly poor the further one travels from the city centre. In these circumstances, private car use is likely to remain the dominant mode of transport.
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Impact on the Local Environment and Biodiversity
Policy PP29 and Policy EN4 – Irreplaceable Habitats
The PP29 site lies adjacent to Pits Wood Local Wildlife Site. The proposed 15-metre buffer is inadequate given the sensitivity of the site and the presence of:
• large badger setts, and
• a population of nesting nightingales, a Red List endangered species.
The Woodland Trust recommends significantly larger buffer zones for development adjacent to ancient or sensitive woodland habitats. It is essential that full, seasonal ecological surveys are undertaken before any allocation is confirmed.
The potential enhancement of wildlife corridors linked to the Roman River corridor is welcomed, but this does not offset the likely harm arising from development at this location.
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Health and Wellbeing – Healthcare Provision
The delivery of Policy ST1(f) relating to healthcare provision is questionable. Local GP surgeries are already operating at or beyond capacity and would be unable to accommodate the additional population generated by approximately 1,800 new homes, in addition to the 630 homes planned in Stanway. There are also ongoing concerns regarding hospital capacity.
Any new development must be accompanied by properly funded healthcare provision, including staffing, to meet the needs of a significantly increased population.
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Community Facilities
Policies CS1 and CS2
Copford Village Hall is a well-used and financially viable community facility. While PP29 refers to its potential replacement, there are serious concerns:
• The Village Hall and associated land are registered with the Charity Commission, yet Draft Local Plan mapping suggests this land could be used for housing or access.
• Any transfer or redevelopment would require detailed negotiations between the developer, the Charity Commission and the current Trustees.
• An alternative approach could involve remodelling the existing hall and improving parking provision.
The local community must be fully involved in any decisions regarding the location and design of a new or improved Village Hall. The existing car park plays a vital role during the school run, helping to reduce on-street parking and congestion on School Road.
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Education Provision
While the inclusion of a two-form entry primary school within PP17 is welcomed, this does not adequately address the combined impact of 300 homes from PP29 and 1,500 homes from PP17. Copford Primary School is already near capacity and would require significant investment to accommodate additional pupils.
There is also no clear information regarding provision for secondary or post-16 education. Local secondary schools are already close to capacity, and the projected increase in pupil numbers cannot be accommodated without substantial new provision.