Colchester City Council’s recent statements regarding the inclusion of Middlewick Ranges in the Local Plan reveal serious missteps in transparency, environmental protection, and the use of ecological evidence. Here, Friends of Middlewick outline key concerns, highlighting inaccuracies, withheld evidence, and the ongoing destruction of critical habitats.
1. Early Allocation Without Ecological Evidence
The council admitted that Middlewick Ranges was allocated for housing in June 2017 before any ecological reports were received or ecological survey data was even initiated. This is a violation of the National Planning Policy Framework (NPPF), which requires decisions to be evidence-led, especially when dealing with sensitive habitats like those found at Middlewick, a Local Wildlife Site (LoWS).
Question for the Council: Why did the council proceed with allocating Middlewick for housing development before receiving the necessary ecological evidence, ignoring national planning guidelines?
2. Inconsistent Treatment of the PBA and Stantec Reports
The council claimed the 2020 Stantec report provided a more “detailed analysis” compared to the 2017 Peter Brett Associates (PBA) report. However, this claim is false. The PBA report was a robust Phase 1 habitat survey, identifying 53 hectares of acid grassland as a Habitat of Principal Importance (HPI). The Stantec report, on the other hand, unjustifiably downgraded 20 hectares of acid grassland to “poor semi-improved” and reclassified 65 hectares of semi-improved grassland as “arable.”
Councillor Andrea Luxford-Vaughan admitted during the Full Council meeting on October 16, 2024, that even the planning inspector was “nervous” about the flawed Stantec report, describing it as “rubbish” and “not fit for purpose”. Despite this, the council continues to rely on the discredited Stantec report to justify allocation and proposed development; inviting developers to acquire the site.
Question for the Council: How can the council continue to rely on a discredited report while dismissing the more accurate PBA report, which correctly identified critical habitats?
3. Biodiversity Net Gain: An Impossible Promise
The council claims that the development at Middlewick can deliver a Biodiversity Net Gain (BNG) of 10-16%. However, this figure is based on manipulated habitat data from the Stantec report, which inflated the BNG score through inaccurate classifications. In reality, Middlewick’s acid grassland is irreplaceable, and any attempts to recreate it would take decades, if possible at all.
With accurate data from the PBA report, it becomes clear that a net biodiversity loss would occur if development were to proceed. The council is therefore in violation of the Environment Act 2021, which mandates that developments must result in a 10% net biodiversity gain.
Question for the Council: How can the council claim BNG is achievable when the ecological data supporting it is based on discredited, manipulated classifications?
4. Withholding of Crucial Ecological Evidence
In July 2022, the council withheld a letter from Natural England, the statutory body responsible for nature conservation, before the Local Plan vote. The letter raised concerns about the ecological impact of the proposed development at Middlewick. It was only made available six weeks after the vote, meaning councillors made decisions without all the necessary information.
This withholding of evidence raises questions about the integrity of the Local Plan process and whether councillors were fully informed about the risks posed by developing on Middlewick’s irreplaceable habitats.
Question for the Council: Why was the Natural England letter, which raised critical ecological concerns, withheld from councillors ahead of the Local Plan vote?
5. Destruction of Birch Brook Woodland Margins
Despite promises in the Local Plan that Birch Brook Woodland margins would be “retained in their entirety,” more than 2 km of these margins have already been cleared by the MOD, including key habitat for species like Dormice and Nightingales. The council has taken no action to stop this destruction, which directly contradicts the promises made in the Local Plan.
The council has a duty to protect Local Wildlife Sites, yet it has failed to prevent this irreversible damage, nor has it sent any warnings to the MOD regarding further destruction.
Question for the Council: Why has the council not taken action to prevent the destruction of key woodland habitats, despite the Local Plan’s commitment to protect them?
6. A Call for Reallocation: Middlewick as a Local Nature Reserve
Given the overwhelming evidence against developing Middlewick, Friends of Middlewick and the Essex Wildlife Trust call on Colchester City Council to remove the site from the Local Plan and reallocate it as a Local Nature Reserve. The ecological value of Middlewick is undeniable, with its 53 hectares of acid grassland, home to rare invertebrates, Nightingales, and Barbastelle bats.
The decision to include Middlewick in the Local Plan was based on flawed and manipulated evidence. It is time for the council to acknowledge this and act in the interest of both the environment and the community.
Question for the Council: Will the council act on the mounting ecological evidence and remove Middlewick from the Local Plan, safeguarding it as a vital Local Nature Reserve?
In light of these serious concerns, Friends of Middlewick urge the council to reconsider its position and prioritize the protection of Middlewick Ranges’ irreplaceable biodiversity over unsustainable housing development. The public deserves transparency, and Middlewick deserves protection.
For more information, contact:
Martin Pugh MCIEEM, Senior Ecological Consultant and Friends of Middlewick Deputy Chair:
martin_pugh@hotmail.com
07738 040457
Richard Martin, Friends of Middlewick Spokesperson
Richardjmartin70@outlook.com
07921 833043