Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

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.
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.
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.
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.
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.
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.
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.