Colchester City Council Preferred Options Local Plan Regulation 18 Consultation 2025

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

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

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

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

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

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