Letter 3 – Middlewick Follow-up

Karen Syrett, Senior Officer for Planning and Place Strategy

Simon Cairns, Development Manager

Sandra Scott, Planning Policy Officer

All Colchester City Councillors

Colchester City Council


Sir Bob Russell

Sir Bernard Jenkin MP

Will Quince MP

James Cracknell OBE

12th February 2024

Dear Officers Karen Syrett, Sandra Scott and Simon Cairns – and All Councillors, to whom this also concerns.

Follow-up letter to the ‘In light of new evidence’ letter (21st December 2023) and ‘The Case for Middlewick’ letter from 17 eminent naturalists (5th January 2024) and supporting documents:


We write to you on the critical and urgent matter of Middlewick Ranges. We hope by now you have had the chance to read the ‘17 Naturalists’ letter courtesy of Essex Field Club and Colchester Natural History Society which will provide you a good grasp of the issues at hand and the now complete discreditation of the Stantec Evidence Base used to justify inclusion in the Local Plan; as well as be able to visualise the site and some of its inhabitants (via photos/maps, see also Appx 2 below). These crucial letters and documents are found here:


This concerns the future of Colchester as a whole – and integrity and reputation of Colchester City Council. It is not a ‘niche issue’; we hope the significance of these letters and additional evidence is now clear to all.

Firstly, we are disappointed that nine weeks after seven experts/ residents and four visiting councillors raised urgent objections at the 11th December HYS; over seven weeks since our 7-page ‘In Light of’ letter; and over five weeks since the 39-page letter by 17 naturalists; we have still not received a response or answers from the senior planning officers to some very urgent, pertinent and legitimate questions and concerns.

This letter addresses several urgent topics and themes critical to the ongoing discussion about Middlewick Ranges. These include significant media attention underscoring its ecological importance, compelling public sentiment expressed through a community poll, the success of a community-led litter pick event, the nomination of Middlewick as an Asset of Community Value and serious concerns over the necessity and implications of proposed ecological surveys for 2024 and associated delay in taking action.

Additionally, we explore a potential compromise through an independent desk study review, a Freedom of Information request to scrutinise the survey brief’s impartiality (in light of the heavy bias in favour of development shown by the previous surveys), the risks posed to the Local Plan itself by the inclusion of Middlewick given the apparent breach of PAS Soundness Tests and the broader implications and dangerous precedent of such a development of a biodiversity hotspot on local and national environmental policy.

Incorporating these themes, our letter delves into the high stakes surrounding Middlewick Ranges, as highlighted by widespread media coverage and community engagement. It raises critical questions about the current and future management of this ecological treasure, scrutinises the decision-making process and its transparency and emphasises the dire consequences of proceeding with development plans. By addressing these issues, we aim to ignite a sense of urgency and responsibility among decision-makers and stakeholders, urging immediate action to preserve Middlewick’s invaluable ecological and community assets for present and future generations. This includes reiterating our offer to meet on ‘the Wick’ alongside CNHS naturalists.

In this detailed and consequential letter, we will cover the followings specific topic:

Executive Summary. 2

1)     Middlewick in the Media – Press Coverage! 6

2)     Middlewick Poll Results: ‘What Do You Appreciate About Middlewick Ranges?. 7

3)     Middlewick Big Litter Pick! 8

4)     Assets of Community Value – Nominating Middlewick! 9

5)     2024 Ecological Surveys (Proposed): An Unnecessary Delay?. 10

6)     A Compromise? – A Independent Desk Study Review Completed: February 2024. 11

7)     FOI Request: Past and Present Survey Brief… a Presumption for Development?. 12

8)     Deliverable and Developable? Or Neither? (Middlewick Endangers the LP!) 12

9)     Middlewick: a Puzzle Piece… or a Rotten Apple? (How to take it off the Plan!) 13

Mechanism/Procedure to Remove Middlewick from the Local Plan. 13

10)        A Catastrophic and Perilous County and National Precedent 14

11)        How Did We Get Here? A Review of Circumstances Leading to Inclusion of Middlewick. 15

12)        The Myth/Threat of ‘Speculative Development’ and ‘2000 Homes’ 15

13)        Undervaluing Middlewick (NOT Brownfield!) and Councillor ‘Nimbyism’ 17

14)        The ‘Withheld’ Letter – Scrutiny Committee… and Questions Which Will Not Go Away!  18

15)        Middlewick’s Value was Well-known Even Pre-Local Local Plan Allocation. 19

16)        Does South Colchester Deserve a Nature Reserve? (Less Affluent Communities) 20

Additional Omissions and Failures of the Stantec Report 21

Conclusions: What Next? A Wish to Collaborate to Remove Middlewick from the Local Plan! 22

Resources: 24

Appendix 1 – POLL RESULTS: ‘What Do You Appreciate About Middlewick Ranges?”. 25

Appendix 2 – Middlewick and Weir Lane Grasslands in Context inc. Roman River, Colne & Friday Woods SSSI 26

Appendix 3 – Summary of the Technical Letter from 17 Naturalists. 27

Appendix 4 – MoD Sale of Middlewick Letter 2016. 30

Appendix 5 – ‘Withheld’ Natural England Letter 2022 Summary/Analysis. 32

Appendix 6 – Diane Appleby Letter, January 2024. 33

Appendix 7 – Additional Comments from Colchester Residents. 35

Executive Summary

We have summarised the key points in the letter here for those short of time – but please do make time to read the entire letter, ‘the Devil is in the detail’ as they say and there are important and actionable points.

1) Middlewick in the Media – Press Coverage!

Middlewick Ranges has attracted significant media attention, highlighted in a BBC Radio Essex interview, Channel 4 News, Guardian and Gazette coverage. These outlets have variously described it as a ‘wildlife haven’, ‘beauty spot’, ‘ecological marvel’ and ‘jewel in Colchester’s ecological crown,’ showing how Middlewick is valued and the urgent need for protection in the face of development threats. This local and national media attention will only escalate as the threat under the Local Plan continues.

2) Middlewick Poll Results: ‘What Do You Appreciate About Middlewick Ranges?’

A recent poll in the ‘Save the Middlewick Ranges’ Facebook group, with over 300 participants casting 2,670 votes, reveals strong public sentiment for saving Middlewick Ranges. The poll showcases the diverse appreciation for the site beyond just dog walking and natural history, highlighting its significance for wildlife, combating climate change, education, children’s play, mental health and more.

This overwhelming community response, where 86.4% of respondents identify Middlewick as their most frequented natural space, underscores the critical role it plays in the lives of Colchester residents, challenging the decision to build on one of Colchester’s few remaining green, biodiverse and wilder spaces.

3) Middlewick Big Litter Pick!

A huge Middlewick Litter Pick was held on January 27th, a significant community event that brought together over 40 people, ranging from the young to the elderly. Participants included the Colchester 6th Form College Conservation Group, Colchester Litter-pick, Save Middlewick members, En-form charity, members of the public and James Cracknell OBE. Together, we collected over 20 sacks of rubbish and recycling from Middlewick!

4) Assets of Community Value – Nominating Middlewick!

Middlewick Ranges has been nominated as an ‘Asset of Community Value’ in Colchester, recognising its substantial contributions to both community well-being and ecological diversity. This nomination underscores Middlewick’s role in enhancing physical and mental health through its natural grasslands and trees, acting as a ‘green lung’ for the community. It is a hub for social interaction, educational activities and nature appreciation, aligning with upcoming educational reforms like the GCSE in Natural History.

Ecologically, Middlewick Ranges stands out as Essex’s largest continuous acid grassland, supporting a variety of specialist species. It is home to diverse invertebrates, including nationally threatened species, and provides critical habitat for rare birds and bats like Nightingales and the Barbastelle bat. The area also serves as a crucial wildlife corridor, aiding in climate change adaptation and maintaining ecological balance. This nomination reflects Middlewick’s integral role in both the local community and the broader landscape.

5) 2024 Ecological Surveys (Proposed): An Unnecessary Delay

The proposed 2024 ecological surveys for Middlewick Ranges are seen as unnecessary considering the overwhelming evidence already at hand and the extensive refutation of previous findings by a wide array of experts and conservation organisations (in total over 20 individual experts/ organisations!).

We fear that further surveys and associated delays removing Middlewick from the Local Plan can leave the door open to a developer to purchase encouraged by the allocation of up to 1000 houses under the existing Local Plan; and are considered to be a costly formality or, worse, may be a strategy to delay action until the site is purchased. This scepticism is rooted in years of perceived obfuscation and lack of transparency from decision-makers; we call for immediate, decisive action based on comprehensive existing evidence.

6) A Compromise? – An Independent Desk Study Review Completed During February 2024

As a potential compromise, if CCC still wishes to involve an independent ecologist for the Middlewick Ranges, a focused desk study review is proposed. This review would analyse all information provided by experts and nature organisations (450+ pages) against the Stantec report, ensuring the brief excludes any bias or presumption for development. This approach aims to prevent unnecessary, prolonged surveys/reports.

The review would address key questions about legislative adherence, mitigation hierarchy compliance, the feasibility of habitat replacement and the viability of achieving Biodiversity Net Gain, among others.

7) FOI Request: Past and Present Survey Brief… a Presumption for Development?

A Freedom of Information request has been submitted to obtain the original 2016/17 contract and survey brief and the current terms for the independent ecologist’s survey. This request aims to determine if the 2023 survey brief has been updated in light of recent evidence from various experts and organisations.

Concerns have been raised about whether previous surveys were conducted with a presumption in favour of development i.e. in support of the Local Plan, potentially influencing their outcomes. The request seeks to clarify if the current survey approach is genuinely neutral and independent, free from any predetermined conclusions. Evidence is sought to confirm whether key ecological questions e.g. ‘is mitigation/compensation possible?’, crucial to assessing the feasibility and impacts of development, were ever previously considered.

8) Deliverable and Developable? Or Neither?

Karen Syrett’s statement on 15th January 2024 highlights that the Local Plan is meant to be both ‘deliverable and developable’. However, the inclusion of Middlewick Ranges now poses a significant risk to the soundness and integrity of the entire Local Plan as this site is now shown to fail on both counts.

Given the clear evidence that development at Middlewick would contravene numerous environmental planning regulations and statutory obligations and expert objections have been disregarded, its inclusion fails to meet several key tests of soundness as per the PAS Soundness Checklist, including: Justification, Robust and Credible Evidence, Appropriate Strategy, Effectiveness, Deliverability, Flexibility and Consistency with National Policy.

8) Middlewick as a Puzzle Piece… or a Rotten Apple?

The debate surrounding Middlewick Ranges as a part of the Local Plan is likened to a puzzle, with some planners and councillors insisting that it is an indispensable piece. However, given the recent revelations that the basis for its inclusion is both illegitimate and flawed, there is an overwhelmingly strong argument for its prompt removal.

Middlewick is not just a piece in a planning puzzle but a critical component of the ecological system. Its forced fit into the Local Plan exacerbates issues, like a ‘rotten apple’ that risks further contamination of the entire Local Plan the longer it remains. Prompt action is urged; delays seem to benefit only the MoD/DIO, potentially misleading developers about the site’s viability for development.

10) A Catastrophic and Perilous County and National Precedent

The proposed development of Middlewick Ranges extends its impact far beyond Colchester, potentially setting a disastrous precedent for Essex and England in planning law and ecological practice. This development could lead to the paradoxical notion that Local Wildlife Sites are better protected through development, risking ‘open season’ and the targeting of such biodiverse sites for development under misleading and dangerous conservation claims with an inherent bias and presumption for development.

It also raises concerns about the devaluation of irreplaceable habitats like acid grassland and the misguided belief in their artificial replacement, contradicting Defra guidelines. Additionally, it could endorse risky experimental techniques (such as sulphuring!) for habitat replacement and overlook the consensus of local, county and national experts. The fight to save Middlewick Ranges thus becomes a crusade to uphold responsible ecological and planning principles locally – and nationally. It is a fight which must be won.

11) How Did We Get Here? The Circumstances Resulting in the Inclusion of Middlewick

The inclusion of Middlewick Ranges in the Local Plan is under scrutiny through a Preliminary Review, aiming to uncover how this significant Local Wildlife Site was selected in the first place despite substantial evidence against its development available at the time. Key objectives of the review include understanding the decision-making process that overlooked opposing evidence, identifying the pressures and forces influencing the councillors’ vote and learning how to prevent this being repeated and to protect other vital wildlife sites.

This review, still in its early stages, will delve into public records and private communications from 2016 onwards, focusing on crucial meetings and decisions. Early findings suggest a predisposition towards development, with concerns about the unquestioning adoption of MoD ‘talking points’ such as ‘speculative development’ and Middlewick being labelled ‘brownfield’, raising questions about the transparency and validity of the process. Further insights are expected as the review progresses.

12) The Threat of ‘Speculative Development’ and ‘2000 Homes’

The Preliminary Review will also scrutinise the widely propagated myth about the threat of ‘speculative development’ leading to the construction of ‘2000 houses’. This notion, which has instilled fear in many councillors, suggests the preposterous and dangerous notion that building 1000 homes is the only way to protect this significant Local Wildlife Site. However, this idea is fundamentally flawed and contradicts NPPF guidelines and environmental legislation designed to safeguard Local Wildlife Sites, especially one of Middlewick’s prominence and ecological value.

Ironically, by including Middlewick in the Local Plan, Colchester City Council (CCC) has itself facilitated a form of speculative development, albeit sanctioned under the plan; it has guaranteed impacts not prevented them. This approach raises questions about the rationale behind fearing speculative development on such a valuable biodiverse site. The review will further delve into this paradox, challenging the logic behind the council’s decision-making process and its implications for the future of Middlewick Ranges and other Local Wildlife Sites. A designation as a Local Nature Reserve or Country Park would be a more sensible approach to protect.

13) Undervaluing Middlewick (NOT Brownfield!) and Councillor ‘Nimbyism’

Council meeting minutes and subsequent analyses have highlighted a concerning trend in the undervaluation of Middlewick Ranges’ ecological importance, a trend that predates the now-infamous Stantec report. This misvaluation includes a misclassification of Middlewick as ‘brownfield land’, despite its status as predominantly ancient acid grassland, which contradicts the ecological reality of the site. Additionally, a ‘not in my back yard’ mentality among certain councillors may have influenced decisions, favouring the inclusion of Middlewick in the Local Plan to spare other areas. This approach, coupled with Stantec’s significant underreporting of Middlewick’s ecological value, underscores a systemic disregard for the site’s biodiversity, raising serious concerns about the integrity of the planning process and the need for a reevaluation of Middlewick’s status and protection.

14) The ‘Withheld’ Letter – Scrutiny Committee… and Questions Which Will Not Go Away!

On 28th June 2022, Natural England’s Regional Manager, Justin Tilley, sent a critical letter to Colchester Borough Council’s planning department, emphasising the significance of Middlewick Ranges in relation to the upcoming vote on the Local Plan. Despite this, the letter was not shared with councillors until much later (and only on the insistence of campaigners!), raising serious concerns about the transparency and integrity of the decision-making process.

The withholding of this key document from a major statutory authority has now been referred to the Scrutiny Committee for investigation. This significant oversight prompts questions about whether the outcome of the crucial 4th July 2022 vote, which included Middlewick Ranges in the Local Plan amidst strong opposition, could have been different had the letter been circulated promptly. This situation raises very serious questions!

15) Middlewick’s Value was Well-known Even Pre-Local Plan Allocation

Middlewick Ranges, a Local Wildlife Site since 1991, is known for its significant biodiversity, especially for invertebrates. Despite its recognised ecological importance for decades, the same arguments used to defend Middlewick from development over 17 years ago have been used against development today.

Historically, similar development threats were successfully countered due to the site’s recognised value. In 2006, a proposal for a recycling plant was dismissed, acknowledging Middlewick’s potential as an SSSI and its importance for various protected species, as noted by then Senior Curator at Colchester Museum, Jeremy Bowdrey. This situation highlights the long-known value of the site and the recurring challenge in protecting Middlewick’s sensitive ecosystem against development pressures and commercial ecological reports and advice which are not fit for purpose.

16) Does South Colchester Deserve a Nature Reserve? (Less Affluent Communities)

The message/perception among South Colchester residents from Colchester City Council is clear: they don’t deserve a nature reserve or country park. Developments are unlikely to be approved in affluent areas like Lexden Park, Cymbeline Meadows or Hilly Fields; whilst Middlewick Ranges, located in a less privileged part of Colchester, is seen as an easier target for development. There is a belief that decision-makers assumed there would be less resistance due to its location. However, this has been a gross miscalculation, as evidenced by the strong community response and over a thousand objections lodged against the proposals.

Middlewick Ranges is more than just a green space; for many in South Colchester, it is their only accessible natural area, crucial for mental and physical health and a vital resource for children’s well-being and education. The community’s reliance on Middlewick, including among those without larger gardens, underscores its importance not just as a piece of land, but as a lifeline for the well-being of a significant portion of Colchester’s population. This ongoing struggle against the proposed development reflects a deeper issue of equitable access to natural spaces and environmental justice.

Additional Omissions and Failures of the Stantec Report

Additional inaccuracies and omissions within the discredited Stantec report are being revealed on a weekly basis. The following are in addition to the numerous failures already documented in ‘The Case for Middlewick’ letter by 17 naturalists of 5th January 2024: the report fails to include adequate consideration and impact assessments for Skylark, Barn Owls, Adders, Badgers; and the SPIE mammals Hedgehogs, Brown Hare and Harvest Mouse which are not mentioned at all, despite there being recent records and sightings!

The risk of increased Badger road fatalities, especially in light of North East Essex Badger Group recent records of over 300, is not mentioned at all; neither are the impacts of removing large areas of foraging habitat and likely consequence of forcing Badgers to forage more in people’s garden causing damage and conflicts.

Furthermore, the lack of proper consideration of the impacts on wintering and breeding birds associated with the wider area and residential gardens, alongside discrepancies in the land area for sale by the MoD, highlights a comprehensive and serious undervaluing and downplaying of Middlewick’s ecology and conservation value.


As the risk of a developer purchasing Middlewick Ranges for construction grows daily, the urgency of the situation escalates. Despite stated ‘planning safeguards’, the reality is that council pressure will likely increase post-investment/sale, potentially leading to a devastating development with significant ecological impact. This situation, which could result in a local ‘ecocide’ by destroying one of Essex’s last extensive open acid grasslands, has not yet been addressed with any of the necessary urgency by key decision-makers.

The local community including many experts, having devoted years to this cause, has yet to receive adequate recognition or response from Colchester City Council; ‘snubbed’ and largely ignored.

We urge the council to act promptly and engage in meaningful dialogue with stakeholders, proposing collaboration to remove Middlewick from the Local Plan or to develop a new plan if required that excludes and protects this vital Local Wildlife Site as a designated nature reserve. This letter, along with other documents, will be made public as part of our efforts to bring greater visibility to this critical issue. The contents will also inform upcoming new issues of ‘Middlewick News’ Newsletter.

Now, onto the main letter. Quotes are in green and red; questions to CCC are in purple.

1)    Middlewick in the Media – Press Coverage!

[See ‘Middlewick in the Media’ document attached separately and videos: http://bit.ly/middlewickranges]

Middlewick Ranges has now been called a ‘wildlife haven’ by Channel 4 News, a ‘beauty spot’ by the Gazette, an ‘ecological marvel’ by the Guardian and a ‘jewel in Colchester’s ecological crown’ by the BBC.”

Media scrutiny will only intensify going forward.

As you are likely aware, there has been a flurry of media interest in the campaign to save Middlewick Ranges including an extended BBC Radio Essex interview and coverage, sparked by the letter of objections and concerns by a host of experts. If you missed this then here are links and a previous Channel 4 News feature:

Council urged to take Middlewick Ranges out of Colchester local plan – BBC News

Experts write to Colchester Council over Middlewick Ranges | Gazette (gazette-news.co.uk)

Ministry of Defence under fire for ‘inventing rules’ to sell wildlife haven | Planning policy | The Guardian

Rules to protect wildlife tilted in favour of developers, say campaigners – Channel 4 News

The latter is important from Channel 4 News with Essex Wildlife Trust, the Middlewick section starts at 3.40 but the entire piece is significant on the pitfalls of Biodiversity Net Gain (BNG)… even if applied ‘properly’.

“In this time when we are in a Nature Emergency, the last thing we should be doing is destroying these precious habitats.” – Dr Annie Gordon, Essex Wildlife Trust

“Middlewick ranges in Essex, the proposal here is for 1000 houses. But the wildlife which calls this home will be expected to be put on ice for the 15, 20, 30 years required to try to recreate what’s wrecked.” – Alex Thomson, Channel 4

Once this is destroyed it will take so long for the new mitigation scheme to mature, that the invertebrates – the rare invertebrates – and other wildlife are going to lose their habitat and a lot of them are going to disappear from this area, and could be lost for ever.” – Dr Annie Gordon, Essex Wildlife Trust

“This is acid grassland, a highly specialised and rare habitat; but the plan here is to throw sulphur on a field next door to recreate it!” – Alex Thomson, Channel 4

“The idea that you can destroy sites that have been there providing all these benefits for wildlife for so many years; the idea that you can simply plough that up and create something a few miles away – that’s a very dangerous approach to take!” – Dr Annie Gordon, Essex Wildlife Trust

2)    Middlewick Poll Results: ‘What Do You Appreciate About Middlewick Ranges?

Secondly, we have ‘breaking news’ regarding a recent snap poll launched in the private Facebook group ‘Save the Middlewick Ranges’. This posed the important question: “What do you appreciate about the Wick?”

Over 300 people responded casting 2,670 individual votes! Over 10% of the 3000-strong group voted which is impressive and shows the strength of feeling and how the site is treasured as a public amenity.

We feel the perception by some has been Middlewick is the reserve of dog walkers and ‘boffins with binoculars’. This poll proves overwise, although dog walking and appreciation of natural history is important, you can see there are a multitude of ways in which Middlewick Ranges is valued, treasured, used and loved:

Wildlife and Biodiversity, Fighting Climate Change and Pollution, Interaction with Wildlife, Education, Children’s Play, Mental Health, Dog Walking, No Private Garden, Heritage and Exercise.

In addition, many people took this opportunity to write their own poll question, including numerous pleas to Save Middlewick. Here is one very valid question to all those involved in the decision to build on ‘the Wick’:

“Have you personally heard the nightingales sing in spring/summer?”

A colorful circle with text
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Letter 3 - Middlewick Follow-up

See also Appendix 1 for complete results within a more detailed table.

Child’s Play

The poll highlights, amongst many other uses, the importance of Middlewick for families and children in terms of play and education. Has this been adequately factored into the decision to build on one of Colchester’s last diminishing green spaces? (It would appear not!)  This is from a recent Guardian article:

Children suffering due to lack of outdoor play, UK charities warn | Children | The Guardian

“Children and young people are suffering huge damage to their health and wellbeing from policymakers refusing to prioritise the need for outdoor play, charities have said.”

Every single person reading (and writing) this letter benefitted from having accessible green and wild spaces to play and seek innocent mischief. It helped make us who we are. In condemning one of the last remaining accessible wild spaces such as Middlewick, our generation is ‘pulling the ladder up’. Denying today’s children – and future generations – of this birthright and necessity for mental/physical health.

“We must consider the impact of our decisions on the next seven generations.” – Iroquois Maxum (c 1700)

A second poll asked the question: “Is the Wick the natural and green space that you visit most frequently?”

86.4% of those over 100 individuals who responded stated ‘Yes’.

11.4% of those individuals stated ‘No’.

Additionally, a quarter of those who responded stated they “Grew up with this on our doorstep”.

3)    Middlewick Big Litter Pick!

A wonderful community event took place at Middlewick on Saturday 27th January, with a huge collective litter pick involving over 40 participants – from young to older. This included a large and motivated Colchester 6th Form College Conservation Group, Colchester Litter-pick, Save Middlewick members, En-form, James Cracknell OBE and members of the public. In total over 20 sacks of rubbish/recycling were removed from the Wick!

There was lots of local support with the sounding of horns – and even the very thoughtful supply of biscuits from a local chap who popped into Lidl and dropped them off during our tea break!

This demonstrated the best and the worst! Those minority who carelessly litter – including hundreds of beer cans (now recycled)! And the majority who care deeply and don’t mind getting stuck in to clean this vital nature reserve and open green space.

Colchester volunteers clear litter at Middlewick Ranges and Shrub End | Gazette (gazette-news.co.uk)

A group of people holding signs
Description automatically generatedA group of people holding signs
Description automatically generatedAs we left – as if to remind us of the presence of the natural world – a Sparrowhawk was seen amongst a plume of feathers, tucking into an unfortunate pigeon. The children of course were fascinated! A sombre but vital lesson and education provided by Middlewick; in the location which would be under tarmac and bricks without the vital intervention of a collective of campaign groups, nature organisations and experts!

The real threat and real nature vandalism, of course, stems not from litter; but from diggers and bulldozers which would be sent through the heart of Colchester to destroy this sensitive and treasured site.

4)    Assets of Community Value – Nominating Middlewick!

Middlewick Ranges has been formerly nominated and proposed by en-form as an ‘Asset of Community value’ under Colchester City’s Council’s recent review of such public amenity spaces. The submitted form can be found on the shared documents link: http://bit.ly/middlewickranges.  It includes the following key points:

Community Value and Benefits:

  1. Physical and Mental Health: Middlewick enhances physical health through its grasslands and trees, improving air quality and offering exercise opportunities. It’s a ‘green lung’ for the community, addressing health inequalities.
  2. Mental Health Benefits: Recognised for enhancing cognitive functioning and reducing stress, anxiety, and depression, highlighted during the COVID-19 pandemic.
  3. Community Connection: Acts as a social hub, fostering community interaction and identity, evidenced by activities like dog walking, litter picking and nature walks.
  4. Educational Value: A resource for local educational initiatives, including conservation groups and nature learning, aligning with upcoming educational reforms like the GCSE in Natural History.
  5. Poll Results: A poll from the ‘Save the Middlewick Ranges’ Facebook group highlights its value and appreciation for exercise, children’s play, climate change mitigation and as a biodiversity hotspot.

Ecological Importance:

  • Invertebrate Populations: Home to diverse invertebrates, including nationally threatened species.
  • Acid Grassland Habitat: The largest continuous acid grassland in Essex, supporting specialist species.
  • Protected and Notable Species: Habitat for rare birds like Nightingales and bats, including Barbastelle.
  • Mammal Diversity: Abundant habitat for small mammals, providing a food source for larger predators.
  • Wildlife Corridor: Acts as a buffer for an SSSI and a strategic wildlife corridor, crucial for ecological connectivity avoiding fragmentation and in climate change adaptation.

5)    2024 Ecological Surveys (Proposed): An Unnecessary Delay?

Thirdly – and very importantly: we are deeply concerned about the length of time it will take for additional surveys and reports to be carried out; and that these surveyors may not have been issued with an impartial project brief i.e. they may be working under a presumption of development as Stantec so clearly were.

We are strongly of the opinion that no further surveys are needed. An armada of experts and county/national conservation organisations have come out to forcefully refute and dismiss the now entirely discredited Stantec report and evidence base: Essex Field Club, Colchester Natural History Society, Essex Wildlife Trust, RSPB, Buglife, Butterfly Conservation, Essex Moth Group, Steven Falk (FRES) and 15+ other respected naturalists in Essex, respected lawyers in the field of planning law and a third-party ecological consultancy. Natural England have also spoken out in favour of respecting planning/environmental legislation which should protect this site as well as reiterating its national SSSI level value which has been confirmed by multiple experts.

Can all these experts be wrong in saying any development of the site is not possible without breaching environmental legislations and planning regulations, and without catastrophic impacts on irreplaceable habitats and notable species? And are they all incorrect in stating that the entire basis of the mitigation and compensation proposed by Stantec and DIO is fatally flawed and always has been?

[This could, frankly, be construed to be quite a significant snub to all experts and organisations who have between them spent 1000s of hours pouring over the evidence base and Stantec report; an unenviable task!]

It is likely the most comprehensive analysis and dismantling of any inadequate ecology report in Colchester’s (and Essex’s) history! Middlewick is now one of the most surveyed sites in the District; more species can always be found – but we have more than enough to show national value and certainly sufficient to inform this decision.

The proposals entail ploughing and chemically treating vast tracts of valuable existing grassland (falsely named ‘arable/rye grass ley’) using experimental and unproven methods; in an attempt to ‘compensate’ for the destruction of Essex’s largest remaining acid grassland at Middlewick Ranges – priceless irreplaceable habitats and associated fauna. “One of the most controversial claims” as Steven Falk stated (see 5th January letter).

These proposals by Stantec and MoD – and entire basis for justifying the inclusion of Middlewick in the Local Plan – have now fully unravelled and are observably ‘dead in the water’.

Do we need a 23rd coroners’ report to tell us to stop flogging this already expired and humiliated horse?

With the Council now deferring all decision-making to another ecologist, the following questions arise:

  1. Objective of Additional Surveys: “What specific outcomes does the Council anticipate from commissioning further ecological surveys, given the extensive existing data and expert analyses?”
  2. Expectation from New Ecological Assessment: “Does the Council expect the newly appointed ecologist to provide insights that contradict the comprehensive refutations by numerous esteemed nature organisations and experts?”
  3. Impartiality in Survey Instructions: “How will the Council ensure that the new ecological survey is conducted without any implicit presumption for development, considering past concerns about bias in the survey briefs?”

We are concerned that an additional year of surveys may: i) At best be an expensive face-saving exercise – and ii) At worst, be a way to kick Middlewick into the long-grass, hoping the campaign will go away – and buy sufficient time for a developer to purchase the site and throw their full force towards development.

After seven years of MoD manoeuvring, obfuscation and disregard for concerned expert voices and a distinct lack of transparency and communications from Colchester City Council… who can blame us being more than a little wary and cynical? Decisive action is needed now!

6)    A Compromise? – A Independent Desk Study Review Completed: February 2024

If the Council are intent on involvement of an independent ecologist, then we have a compromise/solution: the appointed ecologist can be commissioned to carry out a desk study review of all of the information provided by experts and nature organisations (436 pages: http://bit.ly/middlewickranges) vs Stantec report (277 pages); whilst making sure their brief/contract excludes any presumption for development in light of this now emphatic and overwhelming evidence which substantiates the evidence presented previously.

This would avoid a protracted period of additional unnecessary surveys and production of further lengthy reports. This could be completed during February/March 2024, and before the extended survey season.

The results would then inform IF further surveys are thought necessary – and if so which surveys. At the moment, Colchester City Council appears to be working on the presumption that surveys are required, which itself is not seemingly based on any qualified ecological advice, in-house or otherwise.

The desk study review would not have to get too ‘into the weeds’; but simply answer the questions 1-9:

Environmental Legislation and Planning Guidelines

  1. Legislative Adherence: “Can the development of Middlewick Ranges Local Wildlife Site be executed in compliance with environmental legislation and planning guidelines including the Environment Act and upcoming Local Nature Recovery Strategy (LNRS), considering its ecological significance?”
  2. Mitigation Hierarchy Compliance: “Have previous surveys and reports adhered to the mitigation hierarchy and National Planning Policy Framework (NPPF) guidelines, especially in the context of preserving irreplaceable habitats?”
  3. Local Wildlife Site: “Considering its status as the third-largest Local Wildlife Site in Colchester District and an invertebrate ‘biodiversity hotspot’, is the development of Middlewick Ranges consistent with CCC’s commitment to biodiversity given their declaration of a Climate and Biodiversity Emergency?

Ecological Impact and Justification

  • Justification for Habitat Destruction: “Given that Middlewick Ranges comprises a significant portion of Essex’s acid grassland (c. 10%), how can its partial or complete destruction be justified, especially when acid grassland is deemed ‘irreplaceable’ under the Defra BNG metric 4.0?”
  1. Acid Grassland Replacement Feasibility: “Is it realistically possible to replace the acid grassland Priority Habitat using Stantec’s proposed controversial and experimental methods, and are there any successful and directly comparable precedents for such an ecological undertaking?”
  2. CIEEM Code of Conduct: Have previous surveys and reports been carried out in accordance with professional guidelines including CIEEM Code of Conduct and Species Competencies?”

Protected and Notable Species and Habitat Concerns

  • Invertebrate Impact Mitigation: “Can the impacts on the diverse invertebrate population at Middlewick Ranges be effectively mitigated using established ecological methods, bearing in mind the national significance and number of species (>1450) and those with conservation status (>165)?”
  1. Biodiversity Net Gain Viability: “Is achieving Biodiversity Net Gain feasible when dealing with the destruction of irreplaceable habitats and on this scale, and does this approach align with Defra guidance and best ecological practices?” (Include a review of Stantec’s controversial DIY metric.)
  2. Translocation of Protected Species: “How realistic and achievable is the mitigation and translocation of protected species, such as reptiles, Great Crested Newts and Badgers, at this landscape scale, considering the impacts on both Middlewick Ranges and the proposed ‘compensation’ grassland?”

These questions should be central to any impartial ecologist’s brief for a site of such importance and significance: informing whether mitigation/compensation is possible: not leaping to how it should be done!

7)    FOI Request: Past and Present Survey Brief… a Presumption for Development?

We have recently lodged a Freedom of Information Request for a copy of the following important documents:

i) The original contract/survey brief(s) for the survey started by BSG and completed by Stantec (2016-2021).

ii) The current contract/survey brief showing the terms of the survey and what is expected from the independent ecologist.

Prior to the issue of these FOI requests, can you confirm that the 2023 survey brief has been updated as a result of the recent additional evidence and objections provided by numerous experts and organisations?

During the past two Local Plan Committee meetings and in answers to Have Your Say questions, much has been made by the responding Councillors and planners of a ‘neutral/independent ecological survey’.

However, is the instruction/brief issued by CCC and terms of the survey ‘neutral and independent?’

Previous surveys indicate the survey brief may have contained a presumption in favour of development or in support of the Local Plan: a presumption that development can and should go ahead, implicit in the contract. This is crucial to pin down and explain what has gone wrong and anticipate any future bias for development.

The survey is only as neutral and independent as the assumptions and expectations of the initial instructions; we hope therefore that the current brief contains no presumption for development.

The perception is as follows: that the process which began in 2016 started with one conclusion and then everything was made to fit this conclusion – the presumption for development. Presumptuous is maybe a more accurate description. (See outline preliminary investigation below).

We are willing to be proved wrong here, please do prove otherwise:

Please can you provide evidence in the form of correspondence, survey contracts or in reports that even one single question of those nine posed in Section 4 above were asked to the ecologists involved, to inform the viability of development? Did anyone ever pose the question: Is it possible to mitigate or compensate?

There is no evidence in the Stantec report or elsewhere in the evidence base that these questions were considered at any stage, nor in communications from planners or councillors. No one involved appears to have contemplated at any stage not building on Middlewick. Please do share evidence to the contrary.


8)    Deliverable and Developable? Or Neither? (Middlewick Endangers the LP!)

“The Local Plan is intended to be deliverable and developable.” – Karen Syrett, 15th January 2024

Middlewick currently endangers the entire Local Plan. As a not insignificant component, now that it is clear that the evidence base is not fit for purpose – and that a development cannot happen without violation of environmental planning regulations and statutory obligations – the inclusion of Middlewick Ranges is clearly unsound; this would appear to violate the following ‘tests of soundness’ as per the PAS Soundness Checklist as linked below (all answered with respect specifically to Middlewick’s position in the Local Plan and therefore its effect on the whole plan):

  • Has the plan been positively prepared i.e. based on a strategy which seeks to meet objectively assessed requirements?                                                                                                                   ?
  • Is the plan justified?                                                                                                                 NO
  • Is it based on robust and credible evidence?                                                                     NO
  • Is it the most appropriate strategy when considered against the alternatives?       NO
  • Is the document effective?                                                                                                    NO
  • Is it deliverable?                                                                                                                        NO
  • Is it flexible?                                                                                                                               NO
  • Will it be able to be monitored?                                                                                           YES?
  • Is it consistent with national policy?                                                                                    NO

Microsoft Word – Colchester Local Plan October 2017 Soundness Self-Assessment Checklist (1).doc (windows.net)

The entire Local Plan may therefore already be compromised due to the erroneous inclusion of Middlewick Ranges based on a faulty and illegitimate evidence base.

9)    Middlewick: a Puzzle Piece… or a Rotten Apple? (How to take it off the Plan!)

“Middlewick is an essential part of the Local Plan puzzle; you can’t just take one puzzle piece out!” This has been the repeated response from certain planners and councillors. We would argue as follows:

i) Middlewick is an essential part of the ecological puzzle, part of the Roman River Valley Complex Living Landscape (LL68). Or maybe more accurately, a crucial supporting piece of an already precarious Jenga tower!

You can’t just take it out! (If you do you face ecological collapse!!)

ii) IF Middlewick is SO crucial a component of the Local Plan, now that the entire basis for its inclusion in the Local Plan has been found to be illegitimate and fatally flawed, and the site is not ‘deliverable or developable’, surely it is in the interests of the Colchester’s Local Plan to remove the erroneous puzzle piece which simply will not fit AS SOON AS HUMANLY POSSIBLE? The longer this rotten apple is left, the more this will spread!

How does any dragging of feet or delaying the inevitable for another one or two years help? This only appears to favour the MoD/DIO who get another few months’ opportunity for a fire sale whilst the superficial perception of Middlewick as a development opportunity still appears ‘on the table’ … even though any well-informed and reputable developer would recognise the high risk and stay well clear.

Mechanism/Procedure to Remove Middlewick from the Local Plan

We now have confirmation as was always suspected that it is possible to remove Middlewick Ranges from the Local Plan and that there are procedural mechanisms to action this:

“I think, what I can say here though is that there is a plan-making process to be followed, we can’t simply remove one site from the plan. We’ve been through this in the past, and there are knock-on implications for doing that. We could do a Focused Review, but even then when we’ve undertaken that, it’s not straightforward and for something as significant as this there really wouldn’t be any merit in doing that because of the knock-on implications and the time it takes.” – Karen Syrett, Local Plan Committee 15th January 2024 (response to Have Your Say question)

There is a contradiction and mixed messaging here, the line is repeated than “we can’t simply remove one site from the plan” whilst in contrast stating “we could do a Focussed Review” confirming there is a mechanism to do exactly that. This may not be ‘straightforward’ and it may take time – but it is likely significantly more straightforward and less time expensive than the alternative in taking no action given the inclusion of Middlewick appears unsound, as shown above and in all evidence and documents provided.

It would be very troubling if there are no procedural mechanisms to remove a site when it has been clearly shown to be included on false pretences and unsound evidence, without councillors being fully informed prior to the votes; a ‘computer says no’ situation.

Even if there is no procedure and the entire Local Plan would have to be withdrawn and a new one issued without Middlewick in it, then we would suggest this is best done sooner rather than later (i.e. now!), having been shown that this is now required, urgent and inevitable.

This would then avoid further delay and allow more time for inclusion of new sites if this is indeed required.

(The current time following the recent review and Call for Sites and Green and Blue Spaces consultation, would seem to be ideal; otherwise, what was the purpose of this review? We are aware there have been a huge number of further objections against Middlewick and many residents and experts proposing the site as a Local Nature Reserve/Country Park protecting Middlewick and a vital public amenity and green space.)

10) A Catastrophic and Perilous County and National Precedent

We believe that the potential development of Middlewick Ranges Local Wildlife Site has implications far and beyond Colchester, both across Essex and more widely across England.

We believe, if the development were to go ahead, it would set a catastrophic and perilous precedent in planning law and in ecological practice.

For this reason, and because Middlewick is a cracking site in its own right, we are resolute and stoically determined to fight this act of land-scape scale ecological vandalism and utter madness until the end – until Middlewick is safely extricated from the Local Plan.

Currently Colchester City Council is (inadvertently/proactively?) sending the following irresponsible and potentially disastrous messages to developers, land owners and other Local Authorities:

  1. Local Wildlife Sites Protection Paradox: The absurd notion that Local Wildlife Sites are best protected by being developed upon. (The number of presumed houses on a LoWS should be precisely 0).
  2. ‘Open Season’ on Local Wildlife Sites: A dangerous precedent that any Local Wildlife Site could be targeted for development, under the guise of reducing a larger proposed housing number, misleadingly portrayed as a conservation victory.
  3. Devaluation of Irreplaceable Habitats: A worrying message that irreplaceable Priority Habitats like acid grassland are expendable in the face of development.
  4. Misguided Habitat Replacement: The erroneous belief that irreplaceable Priority Habitats can be artificially recreated and included in Biodiversity Net Gain calculations, contradicting Defra guidelines.
  5. Risky Experimental Techniques: Endorsing controversial and unproven methods like sulphur treatment to replace Priority Habitats, based on the support of a single cherry-picked expert.
  6. Disregard for Expert Consensus: The alarming possibility of overlooking the collective voice of local, county and national experts in favour of commercial consultancies’ approvals (a classic case of ‘cherry-picking particular ‘expert’ to confirm an existing bias!).
  7. Inconsistent Valuation of Natural Assets: Highlighting a stark inconsistency in how we value our natural assets – announcing a Biodiversity and Climate Crisis, promoting garden bird watches and ‘bug hotels’… whilst dismissing the destruction of an entire grassland ecosystem as ‘progress’.

In short, this sets a horrendous example/precedent for the public and developers/Local Planning Authorities!

In light of these concerns, the fight to save Middlewick Ranges is not just about preserving a local site but about upholding sound ecological principles and responsible planning practices.

The development of Middlewick Ranges would be more than a local loss; it would reverberate nationally and send the worst possible message to developers and the dismayed public alike.

11) How Did We Get Here? A Review of Circumstances Leading to Inclusion of Middlewick

We have started a Preliminary Review into the events leading up to the inclusion of Middlewick Ranges in the Local Plan. Something has gone spectacularly wrong here; and we feel digging deeper into this will help:

a) Expose why and how Middlewick ended up on the Local Plan despite being known to be a Local Wildlife Site (and one of particular size and importance, likely of SSSI calibre!).

b) Why an overwhelming body of evidence contrary to Stantec’s now defunct evidence base was so roundly and comprehensively ignored by key decision makers who should have known better?

c) What forces and pressures were at play to result in a majority of councillors voting for the Local Plan, whilst many councillors also abstained or were absent?

d) Learn lessons of how to prevent this happening to other sensitive and important sites for wildlife.

This Preliminary Review is in its early stages and will progress over the coming weeks with a detailed examination of sources in the public domain such as the Local Plan supporting documents, committee meetings, newspapers as well as information shared privately and in confidence.

Findings will be made available to the Scrutiny Committee, informed by Colchester City Council’s Anti-fraud and Corruption Policy 2022/23.

We will begin in 2016 to 2019 when it appears crucial private and public planning meetings were held on Middlewick and the fate of this Local Wildlife Site appears to have been sealed (or attempted to be).

For example, a pivotal early Local Plan Committee meeting took place on 19th December 2016:

Microsoft Word – pbxizwq5.docx (cmis.uk.com)

The following is taken directly from these minutes, in relation to Middlewick Ranges:

Councillor Tim Young: “… the proposed development on land at Middlewick Ranges would need to be accepted.”

This expresses a presumption in favour of development and worrying degree of certainty prior to any ecological surveys and does not acknowledge the Local Wildlife Site status and biodiversity interest.

Was the fate of Middlewick Ranges decided in 2016 BEFORE any surveys took place? A fair question to ask!

Councillor Peter Chillingworth: “He referred to the recent proposals for up to 1,000 homes on land at Middlewick Ranges and considered this to be a welcome opportunity to deliver much needed infrastructure to the south of the town. He considered that the designation of Middlewick Ranges site as a preferred option would raise questions regarding the need for proposals for West Tey, particularly in relation to the former’s brownfield status in comparison with the green field status of land in West Tey.”

Was Middlewick the ‘sacrificial lamb’ by those not wanting garden village or other developments on ‘their patch’? This is not the only reference to Middlewick being selected if favour of less ecologically valuable sites.

And was Middlewick deliberately labelled ‘brownfield’ to make development more palatable (whereas it is of course unploughed permanent grassland, much more valuable than lower biodiversity arable farmland)?

More to follow…

12) The Myth/Threat of ‘Speculative Development’ and ‘2000 Homes’

The above review will also home in on a pervasive myth and pro-development talking point which has been heavily pushed by MoD and key members of the planning department.

The myth – or more accurately the threat – of ‘speculative development’ paving the way for ‘2000 houses’… and possibly a prison! (See quotes below). This appears to have put the fear of God into many councillors who have rushed to save Middlewick… by building on it!

It is not yet known where and how exactly this originated, and why it was so widely accepted without any critical analysis or challenge without being rooted in planning and environmental law and good practice. However, it is likely closely related to the MoD letter of 16th September 2016 accessed via a Freedom of Information Request (see Appendix 4).

Surely, designating Middlewick a Local Nature Reserve or Country Park would be a better way to protect this biodiversity hotspot than condemning it to a housing estate of 1000 homes?

We have addressed this dangerous notion that building 1000 homes is the only way to protect this sensitive Local Wildlife Site previously in the ‘17 naturalists’ letter and ‘30 Pillars’: http://bit.ly/middlewickranges.

These also tackle the ecological impacts and dangers of building on part of the site, and the resulting habitat fragmentation and edge effects etc. which degrade the whole and make the ecosystem unviable.

In brief, this idea – that allocating 1000 houses is the best or only way to protect Colchester’s most biodiverse and third largest Local Wildlife Site does not bear any scrutiny and is frankly preposterous!

NPPF guidelines, current and emerging environmental legislation exist specifically to prevent development within the Local Wildlife Site network, particularly one of such prominence: known to be of national/SSSI quality as far back as the 1990s by then Colchester Borough Council’s own Senior Curator of the Museum!

Why would an award-winning planning department be so afraid of a landowner gaining planning permission on a speculative basis on a known Local Wildlife Site of such significance? Colchester must be the only Local Authority in Essex to present a conservation strategy of protecting Local Wildlife Sites – by building on them.

The irony of course is that in including Middlewick in the Local Plan, this literally paves the way for true speculative development of up to 1000 houses – all but guaranteed under the Local Plan.

There are few things more speculative than building on a nature reserve (in all but name).

We will not explore this any further here but leave you with a Gazette article which makes for interesting reading. This includes proponents (red) and opponents (green) of development on Middlewick, alongside reluctant ‘yes’ voters (orange):

Local plan committee backs 1,000 Middlewick homes | Gazette (gazette-news.co.uk)

“Karen Syrett, the council’s lead officer for planning and place strategy, told the committee the plan would “tightly control” what development could take place on the Wick.

She told the committee without the plan in place, the MoD would be free to sell the site to a developer with a planning application for 2,000 homes.

Ms Syrett also raised the spectre of the MoD selling the site for another use besides housing.

She said: “I believe in the Braintree district at Wethersfield, the site there the MoD have declared surplus to their needs is being promoted for a prison.

“There’s other uses that could be put forward. Without a plan we can’t control development so well.””

“Lewis Barber was the only committee member to vote against the proposal.

He said he had always had “deep reservations” about the local plan.

My feeling is if we include Middlewick in any way at this point, we will not take it out in any review, it will be in,” he said.

“If we go in with an attitude of we’re adopting and then reviewing, we will review and still have Middlewick.”

He added: “I have confidence that we can defend against speculative development in the short time and I’m also minded on the timing that there’s planning reforms coming up.

“Because of those two factors, my concerns are slightly less than they would have been even a couple of years ago.”

He said Colchester Council had “willingly” put Middlewick in the local plan.

It’s not that we’re here by accident,” he said.”

“Councillor Richard Kirkby-Taylor, who voted for the proposal, said he didn’t believe the vote left the committee “between a rock and a hard place”. “A rock and a hard place implies there is some kind of sunlit uplands you can squeeze your way out into,” he said.

“We are not going to be able to find a solution that works and can keep MiIddlewick from being developed on.

“All we can do is find a way of minimising the damage, minimising the risk and allowing us to review it as soon as we can.””

‘Held to ransom’ is a phrase that springs to mind. Or, as stated in our previous letter on 21st December 2023:

“…as councillors and planning officers you were badly misled and misinformed.

13) Undervaluing Middlewick (NOT Brownfield!) and Councillor ‘Nimbyism’

Minutes of Council meetings have revealed that the undervaluing of Middlewick Ranges began even before Stantec significantly undervalued and under-reported the huge ecological value of Middlewick Ranges; in addition, a ‘not in my back yard’ approach has been used as another justification by certain councillors for including Middlewick; or as a reason for not including their local area in the Local Plan.

Firstly, Middlewick was incorrectly identified as ‘brownfield land’. ‘Brownfield sites’ can be of very high value to wildlife in particular invertebrates, sometimes supporting the Habitat of Principle Importance in England: Open Mosaic Habitats on Previously Developed Land; however, this term is still often used in a derogatory way, writing habitats off as low ecological value compared to ‘green field’ sites.

Irrespective, Middlewick is clearly not a brownfield site, there is very little hard standing or built footprint, the site is almost exclusively semi-natural habitat the majority ancient acid grassland for decades/centuries.

Nether the less, the site was called brownfield on at least one occasion by councillors:

Microsoft Word – pbxizwq5.docx (cmis.uk.com)

“He (Councillor Peter Chillingworth) considered that the designation of Middlewick Ranges site as a preferred option would raise questions regarding the need for proposals for West Tey, particularly in relation to the former’s brownfield status in comparison with the green field status of land in West Tey.” – Councillor Peter Chillingworth

Middlewick is not currently on the Brownfield Register: Brownfield Land Register.csv (sharepoint.com)

Secondly, the following are taken form this document, resulting from the Local Plan Committee Meeting on 2nd October 2017, Chaired by Councillor Martin Goss:

Microsoft Word – vuho4x0p.docx (cmis.uk.com)

“Use low quality agricultural land at Middlewick before high quality at West Tey.” (page 38)

“He (Councillor John Jowers) questioned whether it was necessary to seek up to 200 residential units on Mersea Island if the site at Middlewick and the garden communities proposals were proceeding.” – Councillor John Jowers (page 21)

These meeting notes also lists a significant number of objections on page 49-50, including the following:

“5. Loss of biodiversity and wildlife – concerns over loss of the diverse woodland and heathland habitats and 2 protected species. A Local Wildlife site which warrants SSSI designation.” (page 50)

“He (Councillor Tim Young) explained that the Middlewick Ranges site would not have included in the draft Local Plan if the Ministry of Defence had not decided to sell the site.” – Tim Young, at the time Portfolio Holder for Business and Culture and Deputy Leader of the Council

“The Middlewick Ranges site had a large allocation and the site had been late in coming forward.” – Ian Vipond, Strategic Director Policy and Place (page 10)

‘The Case for Middlewick’ letter written by 17 experts, and the supporting ’30 Pillars’ document show the numerous ways in which Stantec under-reported and undervalued the significant wildlife value of Middlewick Ranges Local Wildlife Site. See http://bit.ly/middlewickranges

14) The ‘Withheld’ Letter – Scrutiny Committee… and Questions Which Will Not Go Away!

We would like to formerly submit this letter – with special focus on this section and Appendix 5 (‘Withheld’ Natural England Letter Summary and Analysis) to the Scrutiny Committee’s Investigation into this matter.

On 28th June 2022 Natural England’s Regional Manager Justin Tilley emailed a crucial letter to the planning department, addressed to Sandra Scott; this related directly to the Local Plan and Middlewick’s inclusion in advance of the crucial vote which he referenced, reiterating the ecological importance of the site.

On 4th July 2022 Colchester Borough Council held this crucial vote to seal the deal on the Local Plan which included Middlewick Ranges despite vehement opposition by experts including Essex Field Club, Essex Wildlife Trust and Colchester Natural History Society and vociferous opposition from Colchester residents.

However, this letter – from the key statutory authority and responsible body – was not seen by the councillors until months later, and then only as a result of pressure from campaigners.

Why was this key document not immediately circulated to councillors to inform the vote?

Would this important letter have resulted in a better-informed vote and possibly have changed the outcome?

These and other troubling questions still loom large, even before a more forensic ‘postmortem’ has begun.

The apparent withholding of an essential piece of evidence and information from the most important relevant statutory body, Natural England – was referred to the Scrutiny Committee on 22nd January 2024.  

We also include quotes from a relevant article – which appears to raise more questions than it answers:

(How can councillors ask for a letter… which they did not know existed? And why was the vital importance and significance of the letter diminished and played down as ‘just another email’?)

5th October 2022 Gazette article:

Middlewick campaigners say council officials concealed letter | Gazette (gazette-news.co.uk)

“One could reasonably expect that such a strong letter might have changed the way the council intended to vote or councillors’ own decisions.

“In the end councillor Goss and the mayor, councillor Tim Young, both agreed this letter would be made available to councillors after the vote took place.

“Even now, three months after the vote took place, it hasn’t been apparent this promise has been fulfilled.”

He added: “Colchester residents may now be wondering why the letter was kept from councillors and their own portfolio holder for planning by their own department.

“I do find it astonishing a campaign group has to provide information to a councillor that their own department saw fit to keep away from them, before and after a crucial vote took place.”

“Planning officer Karen Syrett said anyone who had asked for the letter had been provided with a copy.

She added: “We don’t tend to just generally circulate everything that comes into our inbox, I had 150 odd emails today – I’m sure councillors don’t want to receive a copy of everything I get.

“Having said that, I would apologise if the chair and/or the mayor asked for it to be circulated to everyone, I am happy to do that.”

See Appendix 5. The Natural England letter in question [1-2] is found here: http://bit.ly/middlewickranges 

15) Middlewick’s Value was Well-known Even Pre-Local Local Plan Allocation

Councillors have stated: ‘knowing what I know now, I would not have voted for Middlewick’s inclusion in the Local Plan’. However, it is important to point out that – although surveys have further confirmed the national level value of the site – Middlewick has been known for decades as site of high biodiversity value in particular for invertebrates, recognised as a Local Wildlife Site since 1991 (reviewed in 2008; extended in 2015).

Practically the same defence for Middlewick is being made now by the natural history community – which was also made 17 years ago, defending the site from the development of a recycling plant in 2006.

Since this time, we have significant additional records – and Colchester has become a City and declared a Climate and Biodiversity Emergency; and the State of Nature report has come out confirming the devastating loss of wildlife in this Nature Emergency making sites like Middlewick even more important.

Yet somehow, Colchester City Council has managed to bow to pressure and condemned this most precious of Local Wildlife Sites, of national value, to up to 1000 houses (or rather, attempted to condemn).

In 2006 the Council listened and dismissed the inadequate report and damaging proposals.

In 2006 there was a proposal for a recycling plant on Middlewick; this was dismissed at least in part due to the high wildlife value and traffic, documented at the time by Colchester Museum Senior Curator Jeremy Bowdrey:

“Application No: M/COL/06/1401

Date Received: 14th August 2006

The Council’s Curator of Natural History has responded as follows:-

“The area under consideration forms part of the County Wildlife Site (SINC G31) as identified in the Borough Plan. Middlewick Ranges is one of the premier wildlife sites in the Borough of Colchester, particularly important for its invertebrate populations. In the past English Nature has suggested that the site could qualify for SSSI status.

The use by MOD as a firing range has doubtless protected this area of semi-natural acid grassland from development in the past. The importance of the site is shown by the wealth of species data held in the Museum site file going back over several decades, Historically, most of the recording of flora and fauna has been carried out in the area to the south – east occupied by the butts, because the specialised sandy conditions attract a wide range of fossorial (ground nesting) species of insect and the short sward attracts other specialised invertebrates. However, recent studies have indicated that the area of the ranges under consideration in the north-western part of the site is also of value for nature conservation. It is also likely that invertebrates from the butts area use this area for foraging.

The RPS ecological survey, carried out under unspecified weather conditions on a single day, completely ignores the County conservation designation and merely hints at the possibility of the wealth of biodiversity present on the site. Protected Species – Common lizards (Lacerta vivipara) definitely occur (last sighting August 2005), Badgers are known to have a sett in the vicinity and nesting birds (including skylark) are certainly present in season. Bats use the area for foraging, although no roosts are currently known. As pointed out in the survey, the flora is also of interest and in addition several local species of insect were recorded on a brief survey in August 2005.

In summary, as a point of principle the siting of such a facility on a County Wildlife Site, even on a temporary basis, surely goes entirely against planning guidance. On biodiversity grounds it is unsustainable for such a facility to be located on one of the Borough’s premier wildlife sites. In addition, acid grassland accounts for less than 1% of the Borough land area, protected reptile and mammal species as well as several bird species.”

– Jeremy Bowdrey, former Senior Curator at Colchester Museum (2006)

It seems, in 2006 and over ten years later, inadequate ecological consultant’s reports and uninformed decision making have continued to threaten this sensitive site; thankfully, in 2006 the site was saved. Let us hope similarly that respect for due process, environmental legislation and common sense can prevail in 2024!

16)  Does South Colchester Deserve a Nature Reserve? (Less Affluent Communities)

The message loud and clear form Colchester City Council to the people of South Colchester:

“You do not deserve a nature reserve or country park!”

Whether or not this is the intention, this is the perceived message. Can you imagine a huge development being approved/facilitated via the Local Plan, on Lexden Park, Cymbeline Meadows or Hilly Fields?

(We wouldn’t want to give anyone any ideas!… but the short answer is no!)

So, what makes Middlewick ‘fair game’? Did some of the key decision makers believe there would be fewer objections and less resistance due to the location in south Colchester, a less affluent part of the City?

The perception is that Middlewick Ranges is an easier target for development because it lies slap bang in the middle of the most deprived area within Colchester District.

If this is the case, then this is a serious miscalculation! Well over 1000 objections were lodged. And the community has risen up and fought against this looming threat for over six years now. This campaign and publicity will only increase as the reality of these outrageous and damaging proposals dawn on more people.

Some rely on Middlewick as their only green space as they do not have a garden. Many rely on Middlewick for their mental and physical health, and to support their children’s well-being and education (see poll in section 2 above). This ongoing struggle against the proposed development reflects a deeper issue of equitable access to natural spaces and environmental justice in a less privileged part of Colchester.

Letter 3 - Middlewick Follow-up
Letter 3 - Middlewick Follow-up
Letter 3 - Middlewick Follow-up

Map taken from Colchester Borough Council Green Infrastructure Strategy (2011) – Middlewick marked by blue star

Additional Omissions and Failures of the Stantec Report

The ‘Case for Middlewick’ letter issued on the 5th January 2023 and written by 17 eminent naturalists makes an overwhelming and comprehensive case against the Stantec report, highlighting many inaccuracies and omissions; however, even since this was written further flaws and omissions have been revealed:

  • Skylarks: Several Skylark, Red List Birds of Conservation Concern, are already singing as of 3rd February 2024. Where will they go? (And the many Nightingales which will soon arrive, similarly impacted and another key Red List species.) These two species alone should be sufficient grounds to dismiss the plans for housing. The Stantec report utterly failed Skylark, Nightingale and so many other protected and otherwise notable wildlife, writing them off and disregarding the catastrophic impacts both on Middlewick and the 100ha Weir Lane grassland. It is rare to experience Skylark within a City; their role for mental health and wellbeing locally cannot be overstated.
  • Barn Owls: Known to occur within both Middlewick and Weir Lane grasslands (the proposed ‘sacrificial’ compensation site). Barn Owl are protected in the UK under the Wildlife and Countryside Act (1981) and have suffered significant loss of grassland habitat, a contributing factor to their historical decline. The potential importance of these grasslands for Barn Owl in terms of a food source of small mammals was significantly under-estimated and played down by Stantec who incorrectly said: “grassland is limited in terms of potential value as foraging habitat for species such as barn owls”.
  • Adders: Stantec downplayed the significance of Adders at Middlewick, incorrectly claiming they are widespread and would not hinder development. This contradicts the reality of their scarcity in Essex, low population density and the likely critical habitat Middlewick provides, making mitigation for their loss nearly impossible. We have logged 12 independent sightings of this fascinating species!
  • Badgers and Road Fatalities: The North-east Essex Badger Group reports rising badger road fatalities yearly; this alongside other impacts such as a huge loss of foraging habitat is entirely neglected by Stantec’s report. Development will displace badgers, increasing road death risks by altering their commuting routes and destroying foraging habitat, driving them into people’s gardens causing damage/conflicts as seen frequently in more heavily built up areas such as Basildon and Southend.
  • SPIE Mammals – Hedgehogs, Brown Hare and Harvest Mice: These Species of Principal Importance in England are not mentioned once in the Stantec report; despite sightings and records of all three species. The dramatic impacts therefore on these and other mammals have not been considered.
  • State of Nature Report and Species Extinctions: The State of Nature report highlights a 19% species decline since 1970, 1/6 species facing extinction and a 13% reduction in invertebrate habitat, with significant declines in pollinators/predators like bees and wasps. The loss of Middlewick would lead to habitat loss and possible UK species extinctions, contradicting Colchester’s declared Biodiversity Crisis.
  • RSPB Minsmere Warden: Echoing RSPB concerns, Minsmere’s warden Mel Kemp shares further evidence demonstrating the incomparability of the findings with Middlewick’s mitigation land, opposing the use of Minsmere as a justification for destroying ancient acid grassland.
  • Discrepancies and Concerns Regarding MoD Land Area for Sale: Misleading and changing information about Middlewick’s sale size and the recent exclusion of mitigation land from MoD/DIO plans raise additional serious concerns about security of land management and potential added biodiversity loss.
  • Impacts on peripheral garden wildlife including birds: Development threatens not only Middlewick’s wildlife but also the broader ecological network, potentially diminishing garden bird visits and impacting common species’ survival in surrounding residential areas. For example, by impacting nesting and foraging habitat of birds who spend part of their day/year within residential gardens.

Conclusions: What Next? A Wish to Collaborate to Remove Middlewick from the Local Plan!

As each day passes, the risk intensifies that a developer will purchase Middlewick Ranges with intentions to build, escalating the urgency of this situation. While ‘planning safeguards’ exist in theory, in reality once a developer invests, the council will face increased pressure to approve what would be a devastating planning application; whether this is the full 1000 ‘units’ or fewer.

This could not be more urgent and serious; yet so far, we have seen no evidence at all that the key decision makers within the planning team and Council are treating this with the urgency/seriousness it deserves.

This urgency is compounded by the fact that Middlewick Ranges, a vital habitat for numerous rare and threatened species, is at risk of becoming a local example of ‘ecocide‘ – a term applied to environmental destruction like that seen in the Amazon Rainforest, but also applies to our own equivalent biodiversity hotspots. Whilst we are no longer members of EU, it is not difficult to imagine protections from the reckless destruction of entire ecosystems being eventually written into UK law as well, further protecting invaluable and irreplaceable sites like Middlewick Ranges Local Wildlife Site.

EU criminalises environmental damage ‘comparable to ecocide’ | Green politics | The Guardian

The loss of one of Essex’s last extensive open acid grasslands would be a significant blow to one of UK’s most biodiversity-depleted counties, Essex has been hit particularly hard by development and intensive farming.

Our concerns and questions, raised several weeks ago, remain unanswered. Recent interactions include keeping advocates for Middlewick waiting for 2.5 hours to speak at the Local Plan Committee Meeting on 15th January 2024 (the latest ever Have Your Say?).  There were opportunities after other speakers and a break, this discourteous delay was unnecessary and resulted in one speaker having to leave before they could participate.

This symbolises a broader pattern of disregard and, frankly, contempt towards those defending Middlewick Ranges. Ironically, if the council had heeded the advice and warnings of local naturalists and residents from the start, the current predicament could have been avoided. The local community, having invested years and countless hours into this campaign, deserves recognition and a response from Colchester City Council.

We urge and advise the council to not only listen but to act swiftly to prevent further damage to Middlewick Ranges and the Council’s reputation. Improved communications and respect towards key stakeholders, including Friends of Middlewick, en-form and natural history organisations, are essential.

We propose a fresh start, offering collaboration to either remove Middlewick from the Local Plan or to shape a new plan that safeguards this critical Local Wildlife Site as a Local Nature reserve. It is time for meaningful dialogue beyond brief speeches and letters, recognising the gravity of what is at stake for Middlewick and the broader community.

With this in mind, we would like to again propose meeting with planners and councillors on Middlewick and a round table discussion with key stakeholders involved in collating the evidence and objections in the recent three letters. We are also planning another big litter-pick soon and you would be most welcome to attend. The small and big picture is best explained and experienced on site.

For transparency, this letter and other letters and documents will be placed in the public domain soon as we update our website and bring this campaign more visibly into the public domain. It is difficult to think of a more damaging proposal which is of more public interest than plans to pave over Middlewick Ranges.

We would like to leave you with the honest spoken words of the people of Colchester, taken from comments under the following Gazette article from 2021; some refreshing plain speaking – you do not have to be a professional ecologist or expert to see when something is simply wrong in every single respect.

See also letter from Diane Appleby and comments from other long time Colchester residents in Appx 6 and 7.

Essex Wildlife Trust opposed to 1,000 home estate at Middlewick Ranges | Gazette (gazette-news.co.uk)

“Should be against the law to build on such an important wildlife habitat, we go on about saving the rain forests we should start saving our own wildlife habitats first….” – Pierre Poopole

“People don’t realise that this is a habitat like no other, it is unique in its own right, the land has not been worked for god knows how many years and reverted back to its natural biodiversity, this isn’t just any old land, a farmers field lacks anything special, this is packed with diversity, its also the lungs ring fenced in from the surrounding roads and houses. To build even on some of it is wrong, there’s no infrastructure and not many options if any to even have a new infrastructure. This is just wrong on every level, once this is gone, it’s gone forever.” – John Peters

“It’s not the mods land they never paid for it, they took it. it should go back to the people of colchester if they no longer need it. Make up for the years and years of having to put up with the noise of gunfire.” – omgwtfbbq

“If we keep building house at the rate CBC are allowing we won’t have any countryside or open space left. Time to take stock and save some of our beautiful countryside and wildlife.” – the critic

Best Wishes,

Friends of Middlewick


All letters and documents can be found here: http://bit.ly/middlewickranges

The referenced resources included the following key documents and letters:

  1. [0.1] LETTER 1 – Friends of Middlewick Letter to CCC – ‘In light of new evidence…’ (21-12-23)
  2. [0.2] DOC 1 – MIDDLEWICK OBJECTIONS 1 – Summary of Representations to CCC wrt LP (2019-2023)
  3. [0.3] DOC 2 – MIDDLEWICK OBJECTIONS 2 – Have Your Say Speeches wrt CCC Local Plan (16-01-24)
  4. [0.4] LETTER 2 – THE CASE FOR MIDDLEWICK – Collective of Essex Naturalists – Evidence for LP (05-01-24) (Redacted)
  5. [0.5] DOC 3 – 30 PILLARS – CHALLENGING THE CLAIMS – A Case Against Development of Middlewick Ranges Under LP (v07-02-24)
  6. [0.6] DOC 4 – Acid Grassland in Essex Review – MIDDLEWICK IN CONTEXT 02-01-24
  7. [0.7] LETTER 3 – FoM FOLLOW-UP to CCC – 16 Additional Reasons to Safeguard Middlewick (12-02-24)
  8. [0.8] DOC 5 – MIDDLEWICK IN THE MEDIA – Press Cuttings, Articles & Social Media (12-02-24)

The documents will be periodically updated; find latest versions at the Google Drive link above.

See also supporting documents for the Case Against Middlewick from nature organisations and experts: the best place to start is the summary of wildlife and maps [15 to 17] and [2] EWT; [4 to 7] RSPB, Buglife etc

A field of flowers and grass
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Letter 3 - Middlewick Follow-up

Appendix 1 – POLL RESULTS: ‘What Do You Appreciate About Middlewick Ranges?”

  • Poll held on Save the Middlewick Ranges Facebook Group on 15th January 2024. Data extracted 21st January 2024 (some additional votes added since).
  • Votes within each of the 22 numbered statements are individual people selecting specific ways in which they appreciate Middlewick Ranges.
  • Votes across multiple statements/options were made and did not have to be restricted to one.
  • In total 1670 individual vote choices were logged as of 21st January 2024 from 301 unique individuals (10% of the entire group members!).
  • The poll shows the diverse ways in which Middlewick Ranges is used and appreciated as a utility; and the strength of feeling to protect this site.
Letter 3 - Middlewick Follow-up

*These choices were added later by members of the Facebook group; these may therefore be under-represented as they were not available to tick when many cast their initial vote.

Appendix 2 – Middlewick (Co122) and Weir Lane Grasslands in Context inc. Roman River, Colne & Friday Woods SSSI

Other notable Local Wildlife Sites ecologically connected to Co122 (Middlewick): Co128 (Birch Brook Wood); Co113 (Colchester Cemetery); Co121 (Bourne Valley);

Co135 (Donyland Wetland); Co137 (Hythe Brownfield); Co144 (Rowhedge Pits); Co106 (Friday Wood North); Co110 (Berechurch Grassland); Co120 (Ball Grove).

SSSI = Purple        Local Wildlife Site = Green        Weir Lane Grassland (‘mitigation land’) = Orange        

Appendix 3 – Summary of the Technical Letter from 17 Naturalists

Please see full letter: ‘[0.4] LETTER 2 – THE CASE FOR MIDDLEWICK – Collective of Essex Naturalists – Evidence for LP (05-01-24) (Redacted)’. Sent to all planners and councillors on 5th January 2024.

This crucial letter is also available at the following shared Google Drive:   http://bit.ly/middlewickranges 

Here is a very brief overview and summary of some of the key points made:


  • Context: A collective of 17 eminent Essex naturalists and ecologists appeal to Colchester City Council to remove Middlewick Ranges from the Local Plan, challenging the development proposal based on fundamentally flawed ecological assessments and unsound premise and presumption for development; in short, the impacts on irreplaceable habitats cannot be compensated or mitigated.

Flawed Basis for Development

  • Inaccurate Assessments by Stantec: The Stantec surveys and report, which form the basis for the proposed development, are critically flawed:
    • Underestimation of Biodiversity: Stantec reported only 318 invertebrate species, while Essex Field Club identified 1480 species, reflective of a wider gross underestimation of biodiversity.
    • Misrepresentation of Acid Grassland: Middlewick’s acid and neutral grassland, crucial ecological habitats, are in part mis-identified and given low values in the Biodiversity Net Gain calculations in Stantec’s report, under-estimating the exiting value and over-estimating the proposed ‘compensation’ habitats using experimental unproven methods.
    • Dougal Urquhart (CNHS): Reiterates criticism of the Stantec survey, report and findings from various other experts and organisations including Midland Ecology, EWT and RSPB. The inappropriate survey timing of the botanical and invertebrate surveys are also questioned occurring after a cut and during rain respectively.
    • Peter Harvey’s Critique: Peter Harvey from the Essex Field Club highlights that Middlewick could qualify as an SSSI, and contradicts many of Stantec’s findings.
    • The surveys and report informing the evidence base are found to be not fit for purpose.

Criticism of Biodiversity Net Gain (BNG) Approach

  • Invalid BNG Calculations: Stantec’s BNG metrics are criticised for significantly deflating the value of existing habitats and inflating the value of proposed habitat creation.
    • Net Loss of Biodiversity: Adjusted calculations suggest a Biodiversity Net Loss of -31%, contrary to the required net gain; a 10% gain is not achievable – and Defra BNG is not applicable or legitimate for irreplaceable habitats.
    • Peter Harvey’s Observation: Harvey notes that the idea of enhancing ecology and achieving biodiversity net gain through development lacks independent scrutiny and evidence.

Concerns Over Experimental Methods

  • Doubtful Sulphur Treatment: The proposal to use sulphur to recreate acid grassland at the compensation site near Weir Lane is scientifically dubious and highly controversial.
    • Steven Falk’s Concerns: Falk, an authority on invertebrate conservation, expresses alarm at the claims of recreating high-quality ancient acid grassland; this cannot be achieved.
    • RSPB’s Refutation: RSPB refutes the use of their Minsmere study by Stantec, emphasising significant differences in objectives and soil conditions.

Ecological Value of Middlewick Ranges

  • Biodiversity Hotspot: Middlewick is described as a vital ecological area with a rich ecosystem, supporting a wide array of species and habitats.
    • Dr. Jeremy Dagley, Essex Wildlife Trust Statement: Dagley emphasises the site’s ecological importance, particularly for acid grassland and urges removal from the plan on behalf of both Essex Wildlife Trust and Essex Ecology, formerly EECOS, who formerly signed off the Stantec report as CBC then acting ecologist (thereby removing the essential third party validation for the report making it in effect null and void).
    • Rob Smith’s Emphasis: Smith from Butterfly Conservation stresses Middlewick’s national ecological importance reiterating points from many other experts and organisations recognising the site for its astonishing invertebrate biodiversity supporting many threatened species.

Call for Action

  • Urgent Protection Needed: The letter urges the Council to fully protect Middlewick Ranges and consider alternative housing allocations.
  • Collaborative Approach: The experts seek to work with the Council to preserve wildlife-rich spaces amid a biodiversity and climate crisis.
  • Eight Questions: Eight urgent questions are posed including the following topics: Justifying Inclusion Despite Ecological Value, Feasibility of Safeguarding Biodiversity, Reconciling Development with Conservation Principles, Mitigation Strategies vs. Ecological Realities, Adherence to Environmental Legislation, Revisiting the Local Plan Inclusion Criteria, Transparency and Stakeholder Engagement and Green and Blue Spaces Consultation (Amenity Value and Community Use).

Contributors and Quotes

  • Professor Ted Benton FRES FBNA (CNHS): Highlights Middlewick’s irreplaceable ecological and historical value.
  • Simon Wood, Essex Birdwatching Society: Warns of the impact on Nightingales, a declining Red List bird species, including on the adjacent Birch Brook Local Wildlife Site which will also be badly impacted.


The letter presents a compelling case against the inclusion of Middlewick Ranges in the Local Plan, backed by substantial ecological evidence and expert opinions. It emphasises the flawed basis of the Stantec surveys and report, particularly the underestimation of existing biodiversity, the misrepresentation of acid grassland, and the invalid BNG calculations.

The proposed experimental methods for habitat creation are also critically questioned. The collective of experts calls for urgent action to protect Middlewick Ranges, highlighting its ecological significance and the need for a more sustainable approach to development planning which does not target biodiverse Local Wildlife Sites such as Middlewick Ranges.

Selection of important quotes from the ’17 Naturalist’ letter:

“Nobody has ever gone out and recreated a fully functional community. They may have altered the ground chemistry such that the plants can start to naturalise into something approaching a pastiche of the original habitat. But it is only a pastiche. Because you don’t get the rest of the wildlife there. From the microbes up to the invertebrate…” – Dr Chris Gibson FBNA

“Middlewick Ranges is an outstandingly important site for wildlife, not only for Colchester, but for Essex and the wider region. At 76 hectares it is one of the largest Local Wildlife Sites in the area and on its own, represents nearly 4% of the District’s complete Local Wildlife Site acreage. With tens of hectares of rare acid grassland habitat, Middlewick Ranges encompasses the largest extent in north Essex and is of similar ecological importance to Epping Forest SSSI’s acid grasslands. As Natural England’s letter of 28th June 2022 to your council emphasised, the significance of its special acid grassland is likely to have been underestimated.”[2-2] Dr Jeremy Dagley, Essex Wildlife Trust

“I am astonished and disturbed by the claims that high quality acid grassland can be recreated on unsuitable soils elsewhere simply by adding Sulphur. I would suggest there is a basic misunderstanding of what acid grassland actually is! It is not ‘acidic’ grassland, or ‘acidified’ grassland (i.e. any grassland treated with acid to produce a lower pH).

To suggest that simply adding Sulphur can recreate an ancient soil profile, an ancient seed bank, or ancient (and isolated) plant, invertebrate and fungal communities, is one of the most controversial claims I’ve encountered during my many years working in nature conservation. It should be treated with the utmost suspicion, and expert opinion sought from bona fide grassland, plants and insect experts at Natural England and the wildlife trusts.” – [7] Steven Falk FRES

“I’ve looked at the Stantec report, and one of the things that stands out is the invertebrate study which was done on one visit when it was raining. They admitted that the timing of the botany study was after hay crop had been taken off and also at the end of July; it had been such a hot spell that a lot of the vegetation had already gone over. If you’re doing botanical surveys you should be able to monitor the weather and heating up so much so that you need to get out on survey.” – Dougal Urquhart, Colchester Natural History Society

“No surveys were performed for mammal species by the Stantec study. Of the eight surveys that were done, only two were regarded as “adequate”, two were regarded as “partly adequate” and four as “inadequate”. The Midland Ecology Report concludes that the survey work (and, thus, evidence base) in respect of Dormice, Breeding Birds (especially Nightingale and Skylark), Reptiles, Amphibians and Badgers are to varying extents inadequate.

This undermines the ability to assess impacts, mitigation strategies and Biodiversity Net Gain calculations. These considerations, when combined with the admission that further assessment is necessary, demonstrates that the Stantec Report provides no justification for allocation of the site for housing development.” – [4-1] Colchester Natural History Society statement (page 2-3)

“The Middlewick Ranges is the most important registered Local Wildlife Site (LoWS) in the Colchester area. It has a very high level of ecological value, particularly its invertebrate interest which is well documented, and should be defended from development. The species present demonstrate that the site is of local and national importance and the presence of lowland acid grassland is such a fast-declining resource that it should be given the same protection as lowland heath.” – [8-1] Rob Smith, Butterfly Conservation

“Clearly the whole area encompassing Middlewick and Birch Brook Wood LoWS is exceptionally important for not only the Essex but the national Nightingale population. The Red-listed Nightingale has declined nationally by nearly 50% in the last three decades to some 5,550 singing males.

Any development at Middlewick will result in a clear and obvious increase in disturbance through the construction process, habitat degradation through the proximity of the development itself caused by increased recreation (especially dog walking), noise, lighting, pets etc., all of which will adversely affect this significant population which is likely of comparable size to the largest Essex population around nearby Fingringhoe Wick Nature Reserve, the two sites combined accounting for perhaps 1% of the UK population.” – Simon Wood, President Essex Birdwatching Society

Appendix 4 – MoD Sale of Middlewick Letter 2016

The following document showing the statement and date of the announcement of MoD to Colchester Borough Council regarding the proposed sale of Middlewick Ranges – and the now infamous ‘2000 homes’ threat the MoD attempted to wield against the council in order to attempt to secure 1000 houses under the Local Plan. A myth/threat which the planners appear to have adopted and disseminated to councillors.

The timing also shows how Middlewick Ranges was introduced at very short notice onto the Local Plan with no public consultation at the time and bypassing many of the usual vetting procedures such as sustainability.

Letter 3 - Middlewick Follow-up
Letter 3 - Middlewick Follow-up

Here is the cover letter in response to the 14th September 2016 FOI request:

Letter 3 - Middlewick Follow-up
Letter 3 - Middlewick Follow-up

Appendix 5 – ‘Withheld’ Natural England Letter 2022 Summary/Analysis

The crucial and sensitive Natural England letter of 28th June 2022 was not circulated to councillors in advance of the pivotal vote a few days later. We have highlighted the key points within the letter within the below analysis, showing i) the key messages; ii) the importance of the letter in potentially influencing councillors opinions and iii) the significance of the letter being withheld before this final vote.

The letter: ‘[1-2] Natural England Middlewick Ranges 28 June 2022.vf’ can be found here:


Analysis of the Letter from Natural England to Colchester City Council: 

Implied Key Messages: 

  1. Statutory Duties and Biodiversity: Natural England emphasises the importance of considering the full ecological impact of developing the Middlewick Ranges and the necessity of upholding statutory biodiversity duties. They imply that the council must thoroughly assess and prioritise the site’s ecological significance in decision-making. 
  2. Significance of Middlewick Ranges: The letter points out the site’s considerable importance for diverse and abundant invertebrate fauna, including rare and notable species. This underscores the site’s ecological value, which may not have been fully recognised earlier. 
  3. Challenge to Development Consent: Natural England notes the significant challenge of securing development consent at Middlewick Ranges due to its ecological value. This implies that any proposed development would face considerable scrutiny and potential opposition. 
  4. Requirement for Comprehensive Data: The agency stresses the need for the most up-to-date and complete ecological data to be considered. This suggests that previous data might have been incomplete or outdated, which could have led to an underestimation of the site’s ecological value. 

Importance of the Letter in Influencing Councillor’s Opinions: 

  • The letter could have significantly influenced councillors’ opinions by highlighting the ecological importance of Middlewick Ranges, which might not have been fully appreciated. 
  • It would have presented a strong argument for reconsidering the development, based on ecological significance and legal obligations towards biodiversity conservation. 
  • The emphasis on new data and significant biodiversity interest could have prompted a more cautious approach to the decision-making process, potentially swaying opinions against the development

Significance of the Letter Being Withheld: 

  • Withholding the letter from councillors before the vote could be seen as a significant omission, as it contained critical information relevant to the decision-making process. 
  • The letter’s insights into the site’s ecological value and the council’s statutory duties could have led to a more informed and potentially different outcome in the vote
  • The absence of this information may have prevented councillors from fully understanding the ecological implications and legal responsibilities associated with the proposed development, potentially leading to a decision that didn’t consider all crucial factors

Appendix 6 – Diane Appleby Letter, January 2024

The below letter is just one of several hundred letters, emails and other comments and objections against the destruction of Middlewick Ranges from local residents.

It is, however, a particularly powerful and eloquent testimony and statement which encapsulates much of the love and memories so many of the residents of South Colchester share for Middlewick – as well as the deep level of anger and frustration that this local wisdom and these pleas have been roundly ignored.

Diane’s letter, January 2024:

“To the Councillors, Colchester City Council

Dear Mr/Ms Councillors

As you are aware there is grave concern amongst the residents in the vicinity of Middlewick Ranges about the proposed development of some 1,000 houses on this land.

Since time immemorial Middlewick has been the home to a huge diversity of fauna and flora, many of which are protected species as pointed out in correspondence from experts in the field. No efforts to achieve BNG on this land will be successful. The acid grassland alone is very rare. What Developer will want to return year on year to test the PH of the soil after sulphur etc. has been used to create this acid grass elsewhere in the area?

Middlewick has been, also for time immemorial, a place for people to enjoy the benefits of nature: Dog walkers, runners, joggers, walkers, students, nature lovers, a place where children can play safely, and somewhere to breathe in the clean air of what is the ‘Green lung’ this side of Colchester. It was a God send for the mental health of people in this area.

Should a development take place the residents of three sides of the Wick will be condemned to years of air, light and noise pollution. There is no access road to cope with the heavy plant machinery necessary for building works. The pollution and loss of habitat on the Wick will also have a knock-on effect on the neighbouring SSSI.

Traffic in the Abbot’s Road and Mersea Road area would become even more congested than it is already.

Please take Middlewick off the Local Plan. When it was offered up in letters between CCC/MOD in September and October 2016 we, the public were not consulted.

Yours Sincerely,

Diane Appleby.”

Here is a short introduction to Diane and her relationship with Middlewick Ranges, both personal and unique at the same time having much in common with so many others who appreciate this site as a vital public amenity, open green space and biodiversity hotspot.

“In 1980 my husband completed his Army service and we bought our first ‘Own’ home in Cairns Road. Our home backed on to the Wick which was a big factor in our decision to buy it. At the bottom of our garden there was a small field with three horses in it, and we saw many other species; rabbits, hares, birds, butterflies, bees, bumble bees and other wildlife, too many to record here.

Occasionally, one of the mayors would fall, and there was a vixen who had cubs every year. Sadly, a violent storm one night swept the bridge away and horses were taken away.

The stream was always teeming with frogspawn in Spring. There were frogs everywhere for a while. In the stream were tiddlers, newts, dragonflies hovering on the surface, and so many other insects. Picture our four sons faces when they saw all this, and imagine how much they, and practically every other child in the area, appreciated this it to lick ‘playground’. Imagine the parents knowing their children were playing in an area free of cars. All kinds of games were played out over there, dens were built, trees were climbed to name just two.

After the horses were taken away the field gradually became covered in shrubs, undergrowth et cetera. One day the MoD erected a huge boundary fence which cut off access to the Wick in our area. For those who haven’t a car and cannot walk it was a sad day.

Meanwhile we were both working but it was a joy to come home, snap on our labradors lead and ‘walk the Wick’. Friends were made amongst the dog walkers and those carrying out other activities. It gave people the means to breathe in fresh air, and to socialise. I retired 23 years ago.”


Appendix 7 – Additional Comments from Colchester Residents

The following comments taken from below relevant Gazette articles on Middlewick Ranges, are insightful and also reflective of the wider opinions of Colchester residents, both those who regularly frequent the site and those who may never have set foot but recognise the scale of the problem and the irresponsible paving over yet another biodiverse green space and Local Wildlife Site. These views are personal, honest and forthright.

MoD: Colchester’s Middlewick Ranges goes on the market | Gazette (gazette-news.co.uk)

A response to news that Middlewick Ranges had been put up for sale. 1st November 2023.


Public sentiment strongly criticises the council and government for neglecting community welfare, highlighting the vital ecological and recreational role of Middlewick Ranges and the impracticality of local infrastructure to support proposed housing developments. Comments express disappointment in local planning decisions, the need for preserving green spaces for future generations, and scepticism about the effectiveness of public consultation in the planning process. Concerns about overdevelopment, lack of amenities, and the potential for increased traffic and environmental damage underscore a collective call for accountability and preservation of the site.

“This is a travesty. Neither the council or the government give a $hit about the very people it should be serving. The Wick is a lung for this densely populated area with no change of infrastructure possible. They all go on about environmental damage and they’re at the forefront of going green, total bu11shit! It’s never too late to U-turn. The only thing that’s going to delay this building work is the state of the economy atm and it will get worse.” – The People’s Party

“Just imagine the construction lorries hurtling down Mersea Rd towards St Botolphs. And Abbotts rd onto the Old Heath Rd junction next to the school and then along Whitehall into the Hythe. A nightmare for years.” – Oscar Foxtrot

“So much for having a minister as our MP. Its just lip service. The town has been over developed for far too long, turning it by population alone into a city (not amenities). How could Mersea road and Old Heath road cope with this mass of houses, let alone the schools?” – superhuey70

“The planners should not have designated this area for housing in the first place, they developed and approved the Local Plan. Colchester Planning Department continues to fail the people of Colchester.” – Joe Jacobs

“There should be zero development, and this wonderful Biodiverse piece of land should be made into a country park for the benefit of generations to come.” – John Jones

“The definition of NIMBYism.” – Radio3Man

“Not really. We all need green open land for our physical and mental health. There are no services in the area except Lidl and a cemetery. No doctors and the schools and dentists are full. The roads are already full and it’s impossible to improve them.” – Oliver Guiness

“How many of the people who want it saved actually took the time to take part in the local plan consultation and made their views known before the local plan was decided.” – Phil Delaney

“Every one in Colchester could have submitted their objections, would not have mattered because we don’t matter, all that matters is rich getting richer” – omgwtfbbq

“That my friend is not the point, we have elected representatives to protect their constituents interests. Collectively, Colchester City Council has failed the very people it is empowered to protect.” – Joe Jacobs

“We already own it, MOD never bought it off us. it was common land we all owned it… it was common land where people were allowed to graze livestock.” – omgwtfbbq

“You can be sure that when a plan comes in locals will hold the developers and council’s feet to the fire and ensure all the inspector s conditions are met to the letter. It will be uneconomic to build on.” – Oscar Foxtrot

Middlewick Ranges in Colchester debated in parliament | Gazette (gazette-news.co.uk)

Middlewick Ranges in Colchester debated in parliament. 12th December 2023.


Discussions around Fingringhoe Ranges and Middlewick highlight the community’s frustration with decisions leading to proposed housing developments, emphasising the opportunity to transform Middlewick into a nature park for public benefit. Debates surface on funding and maintenance of such a park, with suggestions that minimal investment is required and that organisations like Essex Wildlife Trust might support.

Critics of development underscore the inadequate infrastructure to support additional housing and the ecological importance of preserving natural landscapes, advocating for responsible planning and community engagement over development.

“Fingringhoe Ranges was earmarked for a future firing range a long time before the fence went up. Ridiculous to blame ‘Colchester’ residents for the fact that because of their irresponsible actions the site now has to have 1000/2000 houses on it! Now that there is no more firing at Middlewick all the more reason to make it a Nature park for the benefit of Colcestrians. And to all the councillors who voted for development (the list is on Facebook) WALK OVER THERE AND SEE HOW AMAZING THE AREA IS AND SHOULD NEVER EVER BE DESTROYED!” – Ronald G

“Whose going to fund your nature park? who will be responsible for keeping safe for users?” – Phil Delaney

“Well Phil, if there is no more firing at Middlewick (as has been the case for years now – the MoD have moved firing to Fingringhoe) why the worry about keeping it safe for users! Secondly, if there is a will and a way a Nature Park needs minimal funding – Nature doesn’t need help – it’s been here for millions of years for God’s sake. Lastly, do you really think that in this day and age we can just concrete over woodland, fields, streams, wildflower meadows willy-nilly just to satisfy the developers and builders who (if you look all around you in Colchester) build crud houses made of tickytacky and sign an amazing natural paradise to death. Why???? When that is destroyed where the hell do you stop!!” – Ronald G

“Minimal funding or not who will be funding it? if the area is going to be used by the public who will pay for the public liability insurance, who will make sure that the nature park doesn’t become a fly tippers paradise. If people want a nature park so be it but need to know where the money for it is coming from.” – Phil Delaney

“The funding could easily be found even in these tight times. Essex Wildlife have offered funding and there are many national organisations that would be willing to ‘chip in’ and it is worth remembering that if it hadn’t been for a generous benefactor (who had a vision of Colchester in the future) we wouldn’t now have the Castle Park. And another thing – the infrastructure in this part of Colchester is already collapsing so if there are 1000/2000 houses meaning 2500 and 5000 cars can you really imagine what gridlock and traffic jams there would be along Abbots Rd, Old Heath, Mersea Rd and Berechurch Hall Rd ! Hell on Earth!” – Ronald G

“Never said about anything about wanting houses being built. If it gets turned into a nature park then fine with that. Just not fine with people who come up with ideas but don’t explain how their ideas are going to be funded or how their ideas will actually work.” – Phil Delaney

“It wont need public liability insurance, like beaches forests, the Yorkshire downs and dozens of other places dont need it.” – The old sea dog

“CCC added it tot the local plan, rather than fight it, they just accepted it was going to be used for housing. Had they have fought for it to stay as fields, then they would be in a better position now.” – We live in a free country

Colchester Council passes plans which could see Wick built on | Gazette (gazette-news.co.uk)

Councillors for Local Plan which includes Middlewick Ranges. 6th July 2022.


The controversy surrounding the inclusion of Middlewick Ranges in the Local Plan highlights perceived irregular and concerning tactics by Colchester Borough Council (CBC) and planners, including late-stage site addition without public consultation and ignoring the site’s designated wildlife status.

Critics argue CBC’s decision bypassed formal processes, leveraging the plan to mitigate speculative development risks at the expense of ecological integrity and community benefit. Discussions emphasise that lands not in the local plan are inherently protected from development, contrary to CBC’s actions, which essentially sealed Middlewick’s fate for development, undermining the plan’s integrity and public trust.

“The blame for the impending destruction of Middlewick lays squarely with CBC councillors who voted the Wick into the emerging local plan in the first place., They did this after the call for sites process had finished and after public consultation regarding proposed sites submitted by landowners inside the published time window had concluded. The call for sites process was closed and work to produce a local plan delivering the borough housing requirement from the plots that had been submitted by landowners inside the required time frame was already under way.

A local plan should be a shining example of local democracy in action, in this case it wasn’t, where was the public consultation prior to Middlewick’s sudden appearance in the plan? There is no legal entitlement to have a plot of land accepted into a plan nor is their any right of appeal when a plot is rejected and the message to the MOD at that point should have been sorry you are too late, besides the land you are proposing is predominantly a designated local wildlife site and as such is “endowed with a presumption AGAINST development”.

Some who spoke last night made much of the fact that not having a plan would expose risk of massive and speculative applications by developers and that is true. Having a local plan protects the land that is in it from over development (because it has a size allocation in the plan) and land that is not in the local plan is protected by the very fact that it is NOT in the plan. Major developments can only be granted planning permission on land that has been allocated for such within the adopted lawful plan, application on land outside of the local plan is deemed as speculative.

CBC could have delivered a viable plan without the Wick but, CBC senior planners (and councillors who saw it as a chance to have less pressure on their own wards if/when the West Tey scheme collapsed) saw its as an easy option. By admitting the Wick onto the emerging plan and planners allocating it for 1000 dwellings CBC ensured that any possibility that the protection against development afforded by NOT being in the eventual local plan was completely lost. From that point on the fate of Middlewick was sealed.

No site accepted onto a plan is subsequently refused planning permission at or near the number it is allocated for, planning is all but rubber stamped once the green light has been shown, its just the minor details that remain to be whittled away by the developers to return maximum profit. Phrases like ‘we will now have control’, ‘master plan’ & ‘delivering the infrastructure’ etc are all complete and utter tosh. History has shown us time and time again what will happen. Medical and educational uplift will be minimal putting more strain on existing facilities and nothing will be done regarding traffic as ECC Highways have already stated the local road network can cope.

The majority of the dwellings built will be out of reach for most local residents. The number of so called ‘affordable units’ will be of low quality, high density, below the target percentage and the bulk of them sold before a brick is laid to London Boroughs and Housing associations, at the end of the process you can guarantee that the CBC housing waiting list will be bigger and longer than ever. Where is the benefit in all this for the residents of Colchester particularly for those who live in the area ? and that’s without even considering the loss of wildlife and open space particularly in the light of CBC’s self declared climate emergency ? Shame on you CBC recent past and present, Shame on you.” – Hervey Benham’s Ghost

“If what you say is true surely it is ground for a judicial review, as CBC acted illegally in their setting out of the local plan?” – road wise

“As I understand it a ‘call for sites’ process is a fairly informal business until a proposed site is legally accepted onto a local plan. A landowner cannot demand their site is included or seek an appeal if it is not. As the matter was not highlighted by the planning inspector we can only conclude that the manoeuvrer to admit Middlewick after CBC had closed its call for sites window was lawful however, it doesn’t take away the fact that as often with CBC and major planning matters it was mighty underhand.” – Hervey Benham’s Ghost

“Land that is not in the plan is not land that isn’t going to be developed. Not including the Wick in the plan doesn’t mean the MoD isn’t allowed it build on it’s own land.” – Christopher Lee

“Agreed but land not in a local plan is far far harder to develop. If a local plan is sound and delivers the required number of dwellings over its lifespan application on land outside the local plan is deemed as being speculative and that is prima facie grounds for refusal. Firms like Gladman’s base their business model on seeking and gaining permission on ‘difficult’ and ‘green field’ sites and thrive in places such as Tendring with no local plan.

Witness the difference in Colchester where at West Bergholt they appealed CBC’s refusal and the planning inspector dismissed the appeal primarily because it was outside the local plan and Battleswick Farm at Rowhedge (where unusually for them they did not appeal) CBC refused for the same reasons. Whilst not being in the local plan does not afford absolute protection it is the biggest weapon in defending and protecting such land and stopping ANY development in its tracks.

That weapon is completely removed when land is included in a local plan and allocated “x number of units” which is what CBC planning officers have contrived to happen regarding the Wick. All that is left to argue about will be the ‘reserved matters’ when planning is now rubber stamped.” – Hervey Benham’s Ghost

“Excellent post, thank you.” – David Brown

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