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

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

Ancient Woodland:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Page 2Forestry Commission

Proposed sites adjacent to Ancient Woodland:

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

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

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

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

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

Policies:

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

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

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

I support the consideration of embodied carbon and the re-use of existing buildings. Too often architects select unnecessary demolition.

West Bergholt Parish Council supports this policy in principle.

We object to Policy NZ2 as currently drafted. While the objective of reducing embodied carbon is supported in principle, the policy is overly prescriptive, insufficiently flexible, and risks undermining development viability and deliverability when considered both on its own and cumulatively with Policy NZ1 and the wider policy framework of the emerging Local Plan. See attachment.

As with NZ1 should the NPPF be adopted with PS13 unchanged, this policy should be deleted as it will be inconsistent with national policy. In addition, HBF have a number of other concerns. HBF do not consider this requirement to be consistent with national policy. In effect this Council are proposing a new technical standard without any formal testing as to whether the development industry can actually reasonable meet this standard consistent from the point at which the plan is adopted. There is as yet limited understanding as whether there are sufficient low carbon alternatives to certain building materials to achieve the standard, the potential cost of meeting this standard and the availability of evidence as to the embodied carbon of different materials and products. Without comprehensive national testing as to what is actually deliverable the Council should not be seeking to impose new technical standard on the building industry.

he Council also do not appear to have taken into account the cost of meeting this standard in the viability assessment. This may have been included in the 8 to 10%. However as stated above, this uplift alongside the £7,500 per unit cost of meeting the Future Homes Standard is probably sufficient to cover the cost of meeting NZ1 and as such no allowance has been made for embodied carbon. As with reducing carbon emissions from operational energy use HBF considers it best that such matters addressed at a national level to avoid different approaches and standard being set in different areas. The housebuilding industry is working with the Future Homes Hub it to develop a roadmap to reducing embodied carbon and whilst Council’s may want to go further faster HBF have concerns that this will impact on the deliverability of development with a disproportionate impact on SME developers.

Therefore, HBF consider the policy to be unsound, and it should be deleted.

TWSL welcomes the ambition of Chapter 7 and Policies NZ1–NZ4 and supports the objective of net zero development. However, it considers Policy NZ2 should align with the Future Homes Standard (FHS) and require homes to be zero-carbon ready, to ensure consistency and support the delivery of market and affordable housing.

While supporting the aim of Policy NZ2 to reduce embodied carbon, TWSL considers the proposed carbon limit and mandatory whole life carbon assessments could adversely affect housing delivery and duplicate existing corporate commitments. It therefore requests greater flexibility, including alignment with the FHS, a requirement to maximise on-site renewable energy generation subject to site-specific constraints, and recognition of developers’ existing commitments to reducing embodied carbon.

Please refer to Lichfields written representations letter obo Taylor Wimpey Strategic Land, dated 14 January 2026.

SEE ATTACHED

Officer summary of full submission. See attachment with detailed comments on numerous policies:
The overall message is one of support for CCC undertaking a review of the adopted Local Plan to ensure an up to date plan prepared in accordance with the NPPF is in place. ECC will continue the on-going engagement with CCC, through the Duty (or any replacement), to assist progress of the Plan to Regulation 19 (the Pre-Submission Plan), particularly with regards the strategic and cross boundary implications, including cumulative issues and opportunities arising from growth to ensure that the infrastructure requirements are identified, quantified, costed and phased where appropriate. ECC service areas have clearly outlined where further collaborative work/assessment needs to be undertaken (e.g. education provision and ongoing transportation modelling) to refine and resolve an issue; and ECC will continue to be engaged, alongside NH, on the proposals which have an impact on the A12 strategic transport corridor, in particular A12 junctions 25 to 28, A12 widening and junction improvements, and the A120 Corridor Maks Tey to Braintree.

There is support for the Draft Plan’s vision which covers environmental, social and economic needs and emphasises healthy living environments and green networks, environmental protection and economic growth. There is support that the mandatory housing target will be met in full and exceeded over the Plan period in accordance with the NPPF, and that future employment needs will be met (noting that some clarifications are sought) by providing a range in scale of additional employment land supply. ECC provides strong support for policies related to net zero carbon (in operation and embodied), water efficiency, health and well-being, and the environment (green and blue infrastructure and BNG. Recommendations are made throughout the response on policy wording (including policy omissions) and justification to strengthen clarity, effectiveness and delivery.

There is strong support for the inclusion of site-specific Place Policies and references to infrastructure requirements, but these will need to be reviewed and confirmed with ECC following this consultation and the agreement of a final spatial strategy by CCC. It is noted there are some omissions in the Draft Plan such as the allocation of a new secondary school. On this issue, ECC acknowledges the requirement is stated in the Infrastructure Assessment Delivery Plan (Stage 3) for site allocation PP18 Land North of A120 Marks Tey; and in the Infrastructure Topic Paper prepared by CCC, where Appendix A lists the infrastructure requirements for the preferred options site allocations (including those for education). Land for the secondary school (and all education requirements) will need to be allocated in the Pre-Submission Plan.

The review of the IDP and full plan viability assessment are key documents for ECC engagement and input following this round of consultation. The Viability Assessment will need to be reviewed following consultation to ensure it can align with the most up to date evidence relating to the EPOA net zero development policies and its viability evidence. Mention is also made in the response to specific localities and sites – notably Marks Tey and Langham – where discussion needs to take place and recommendations are made to ensure effective delivery if these proposed allocations are taken forward to the Pre-Submission Plan.