as previous

Fiddlers Wood is a protected ancient wood. Planning Application 251310 already exists for a site that abuts the woodland. CNHS objected to the development until clarity can be provided on how proposed generous BNG figures will actually provide for the species that are recorded as using the development site.

I strongly object to this site to be included in the local plan for development. This site is far away from the center of village facilities and contributes to ribbon development into our countryside and fundamentally alters the village environment of residents . Inclusion of this site creates a car dependent outlier tacked onto an already poorly served village expansion. The site currently offers locally cherished views over the colne valley which would be lost from local residents and dramatically urbanised when viewed from the north. Bus services during peak times already pass by currently because of poor capacity, many school children currently have no option but have parents drive them to school. Walking routes to the schools shopping and employment opportunities just the other side of the A12 junction are either non existent, a dangerous gamble crossing the junction or a lengthy walk via dark underpass.

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.

The site is potentially located within the setting of four Grade II listed buildings.

Initial assessment

While development here appears broadly acceptable, a proforma Heritage Impact Assessment will help to confirm the site’s suitability from a historic environment perspective and to identify appropriate mitigation measures or opportunities for enhancement. The resulting recommendations should then be incorporated into criteria ‘h’ of the policy.

This site appears wholly unsuited to development by virtue of its prominence on the landscape and views across the valley towards Fordham. This has already been acknowledged by Essex Place Services in the (premature) application for the site by its promoters, which is still being decided. Development of this site will extend the village of Eight Ash Green into the countryside, creating an "incongruous finger" (to coin a phrase from the Grey Belt guidance) and unacceptable impacts on that landscape and adjacent woodland. There are far better sites that were put forward within Eight Ash Green which would support a more nucleated settlement and reduce that impact, whilst maintaining separation between Eight Ash Green and Aldham. They would also be more proximate to village amenities - this site is some way from the primary school, pub and new village hall, which would encourage people to drive. Even sites on the opposite side of the A1124 could have more merit in terms of their visual impact and relationship to the village. I also have concerns around the design quality that has come forward in Eight Ash Green with the Bellway development adjacent to this site - it is not contextual, has limited differentiation of units/styles and feels very urban, especially with all of the street lighting. It would be a travesty to lose such an important view and landscape to something similar and poorly thought out, particularly when other sites are available. Irrespective of the eventual site allocation, the council needs to ensure that its policies and site allocations see development brought forward in a way which responds to character and is high quality.

Comments as follows:
1. Positive to see the Roman River Corridor inclusion, and to see the high value Colne Valley landscapes recognised in the Landscape Character Assessment.
2. Positive to see mobility hubs and increased attempts at providing for sustainable transport.
3. Concern that the Brownfield Land Register remains very limited and focuses almost entirely on the urban area of Colchester. More should be done to proactively identify brownfield sites across the entire city boundary.
4. Concern that affordable housing delivery has only been 16% per annum on average for the past eight years and that the viability appraisals that accompany this plan must be rigrously tested to ensure that they are robust.
5. Concern that the strategy for Eight Ash Green results in car-dependent ribbon development along the 1124. Site PP32 should not be allocated. It represents unacceptable encroachment into the countryside.
6. Further concern that PP32 conflicts with the previous and latest Colchester Landscape Character Assesssments which seek to protect the Colne Valley. The site will be highly visible from Fordham and Chappel and cannot be screened. See attached by way of example. PP32 should not be allocated.
7. Allocation of Marks Tey North. All housing should be concentrated to the south of the site, in a high density development. Much of the Roman River must be kept inaccessible from residents and their dogs to ensure nature can flourish in the Nature Recovery area. The development must be safely connected to Marks Tey station by pedestrian and bike paths that do not use the polluted A120.
8. There should be minimum density requirements for all sites, not just urban ones.
9. The policy wording for conversions should change from 'only supported' to 'strongly supported.
10. There would be a policy to strongly support the bringing back of empty homes into use. An additional SA Monitoring indicator is required for number of homes brought back into use.

I would like to raise a formal objection.

Despite being in Aldham Parish, all of its associated impacts will be felt by the residents of Eight Ash Green with no benefits for the community.

Urban Design – It represents an unacceptable elongation of the village, creating a ribbon settlement pattern

Visual Impact – It would be visually obtrusive, sitting at the top of the Colne valley ridge-line.

Sustainability - Development in this location would unacceptably elongate walk distances.

Traffic Congestion – The A1124 already suffers from significant congestion at peak hours with difficult exiting Wood Lane and Spring Lane

Footpath 4 runs directly through the proposed development and forms part of a wider, well‑established network of public rights of way. Several of these routes extend around and through Fiddlers Wood, an important ecological and landscape asset that must be sensitively retained and integrated into the scheme. This existing network provides a clear opportunity to deliver high‑quality, inclusive, multi‑user routes for walkers, cyclists, and equestrians. Given the scale of development proposed, enhancing and connecting these paths would provide safe, off‑road movement options, strengthen green infrastructure, and ensure the recreational and environmental value of Fiddlers Wood is protected.

This site is in Aldham and not in EAG.
The additional traffic generated will have a direct affect on the A1124 and EAG which is already very busy at times.

The land at PP32 [Land North of Hastead Road and West of Fiddlers Wood, Eight Ash Green] should not be included within the Local Plan as land on which development should be supported.

This is beautiful, rolling, green field land with stunning views, which is in open countryside, in a rural location. It is not, at present, on the outskirts of Colchester. It is not the sort of scrub land, or poor quality land beside a motorway or major road, that is often used for housing development.

It is necessary for all of the detailed and well-founded objections from local people to Planning Application 251310 for permission to build 250 dwellings on this plot of land to be considered carefully and properly taken into account when considering whether it should be included within the local plan.

This rural location is totally unsuitable for a development of 250 dwellings.

Several fundamental errors have been made when categorising this land and considering it for inclusion in the Local Plan, such that its inclusion as a development area in the Local Plan would be highly unreasonable and irrational:

1. It is said to be in Eight Ash Green. In fact it is in open countryside some distance from where any local would consider Eight Ash Green to be.

2. It is obvious from looking at the Local Plan map that this proposed residential development area, and the other proposed area to the south on Halstead Road, closer to the A12 [PP31], both individually and together, are disproportionately large compared to (a) the size of Eight Ash Green; and (b) in comparison with all other proposed development areas on the draft Local Plan map as against the size of the settlements in which they are located. It obviously is out of kilter compared to everything else, and compared to what is reasonable or permissible as a matter of law.

3. The site in fact is within the boundaries of Aldham, not Eight Ash Green. Aldham is correctly categorised as a Small Settlement. Aldham is a rural location which is unable support a development of 250 dwellings.

4. Eight Ash Green has wrongly been categorised as a Medium Settlement. It should properly be categorised as a Small Settlement, and development in the Eight Ash Green area accordingly limited to what would be reasonable and proportionate for such a Small Settlement, which would not involve any development of anywhere near a magnitude of 250 dwellings.

5. The description of a Medium Settlement which is set out at paragraph 12.25 of the draft Local Plan is:

“Medium settlements include settlements with a range of community and social infrastructure … These medium settlements are capable of accommodating growth appropriate to the size, scale and infrastructure of the settlement.”

6. Eight Ash Green does not have a range of community and social infrastructure, and contrary to paragraph 12.31 of the Local Plan it is incorrect and inappropriate to say that “There are a number of local services …”:

a. There is no GP surgery or other health facility.

b. There is no pharmacy.

c. There is no Post Office or bank.

d. There are no cycle paths, and it is too far (8.5km) to cycle to the centre of Colchester.

e. There are no train or tram services.

f. There is a bus service which is close to non-existent. It is very infrequent. It only goes to the centre of Colchester. It does not go to the Tollgate / Stane Park shopping centre which is 3.5km away.

g. The only food shop is a tiny petrol station shop, which is high cost and with an extremely limited range. It is not even sufficient for an emergency/essential shop. It is much smaller than a Tesco Metro or Sainsburys Local. The description of this as a “convenience store” at paragraph 12.31 is inappropriate and misleading.

h. There are no restaurants. There is an unhealthy take away fast food fish and chip shop which stands alone – as opposed to being part of any parade or collection of shops – and which is not open on Sundays and Mondays. It closes at 9pm on the days when it is open. It is a 15 minute walk each way from the proposed site for someone of reasonable health and fitness.

i. The nearest pub is 1.3 miles away from the proposed site, which is a 27 minute walk away for someone of reasonable health and fitness.

j. Contrary to what it paragraph 12.31, it is not that case that there are “hairdressers”. There is a single hairdressing business which operates from a very small mobile unit.

k. There are no sports facilities, indoor or outdoor. There is no gym. There is no library. There is no museum or anything to look at.

l. There is no employment.

m. There is no “centre” to Eight Ash Green.

n. Paragraph 12.31 of the Local Plan says that “Tollgate and Stane park is located approximately 1.5km to the south-east”. This is incorrect. Tollgate and Stane Park is 3.5km from the PP32 site. They are a 45 minute walk away for anyone of reasonable health and fitness.

7. Eight Ash Green is a small dot on the map which is really just a collection of houses. There is nowhere near enough infrastructure to support any substantial number of new dwellings. Anyone who lived in any of 250 dwellings on this site would have nothing to do, and would be totally car reliant. Development on this site would result in huge harm, to the present beautiful, biodiverse environment, and because the likelihood is that it would become a sink, isolated, out of town estate where residents would be trapped without facilities and easy access to Colchester, where high crime would be likely to pervade, in the same way that happened with large developments in Glasgow, Paris and Naples, for example, that were too far from city centres and a long way out of town and cut off from integrated urban life. Lessons must be learned from past planning mistakes. Paragraph 11.23 of the Local Plan recognises that development that is poorly located can have adverse impact on the quality of life of both existing and future residents.

8. Putting housing on this site would increase carbon emissions via car journeys. It would also have devastating consequences for the rural way of life that existing residents of the villages of Eight Ash Green and Aldham – which are small, standalone villages which are not part of Colchester – always have enjoyed.

9. This is supposed to be a “Local Plan”. Inclusion of a development on this site would be contrary to the existence of anything that could be described as a plan, because there appears to be no planning, or even consideration, of whether the location of the development is appropriate, or of necessary improvement in infrastructure to support such a development. If the only infrastructure upgrade that is being required is addition of a new bus stop on the inadequate existing bus route (as seems to be the case), then that is a nothing more than a token gesture, which would be wholly insufficient. On that basis the “Local Plan” would simply be a document giving permission for uncontrolled, unintegrated, damaging development that is not properly thought out, which would not be a rational way or appropriate way in which for a planning authority to proceed.

10. Development of dwellings at site PP32 would be contrary to numerous requirements and principles that are set out in the draft Local Plan:

a. Paragraph 1.3 describes National Planning Guidance objectives:

(a) An economic objective – ensuring that sufficient land is available … in the right places …

This land is in open countryside. It is in entirely the wrong place.

(b) A social objective – to support strong, vibrant and healthy communities … with accessible services …

As set out above, there are no necessary services conveniently accessible from this land.

(c) An environmental objective – … improving biodiversity .. .and mitigating and adapting to climate change, including moving to a low carbon economy.

This would be building houses on pristine farmland, and in light of very poor public transport connectivity and inconvenient location, the development would be entirely car dependent, increasing carbon emissions.

b. Paragraph 2.1 provides: “Section 19(1A) of the Planning and Compulsory Purchase Act 2004 requires local planning authorities to include in their Local Plans "policies designed to secure that the development and use of land in the local planning authority's area contribute to the mitigation of, and adaptation to, climate change".

Development at this site, in relation to which there are no amenities within walking or cycling distance, obviously will increase car journeys, and therefore result in increased carbon emissions, exacerbating climate change, not mitigating it.

c. Paragraph 2.3 says that “The Local Plan is holistic and integrated”.

A plan which provides for development at this site, which is in the countryside in an isolated location and with virtually non-existent public transport and services, cannot be described as holistic and integrated. It would more accurately be described as random, patchwork, without proper integration and without proper regard for the requirement for integration.

d. Paragraph 2.12 provides: “ … it has become a priority of Colchester City Council to spur urgent action to reduce our carbon footprint and promote sustainable urban environments and economies. …”

A large development at this rural site, 8.5km from the centre of Colchester, obviously will increase carbon footprint, not reduce it. This is a completely inappropriate location for such a development.

e. Paragraph 2.13 says: “The Essex LNRS includes a target to double the amount of natural greenspace in Essex. There is scientific research that demonstrates the positive impact that nature has on mental health and wellbeing.”

The site in question, in its present green field form, with wide views over a valley to Fordham, and a public footpath running through the centre of it, it beautiful, and beneficial to the mental health and wellbeing of the many locals who walk on the footpath for the views, greenness and fresh air. It is also positive for the mental health of drivers on Halstead Road, who drive through a beautiful rural location with fields on each side of the road on the way to work, school etc. The proposal to build dwellings on the site would involve concreting over most of it for ever, destroying the views and the greenness.

f. Development at this site would be contrary to the statements at paragraph 2.17 that “Implementation of the Local Plan will make significant contributions towards mitigating the challenges Colchester faces. Addressing the climate emergency, enabling nature recovery … Health and wellbeing and improving quality of life will be woven throughout the Local Plan and considered as part of all proposals in Colchester.

g. Development at this site would be contrary to the themes set out at paragraph 2.21:

• “Protect stretches of undeveloped countryside,”

The proposed development of this side involves large scale building on undeveloped countryside.

• “Improve existing facilities, sustainable infrastructure, green water, wastewater, roads and schools.”

There appears to be no plan in connection with this proposed development to improve infrastructure, roads or schools. The only infrastructure improvement that seems to be being considered is addition of a bus stop on an already inadequate service, which is inconsequential and wholly inadequate.

• “Access to high quality healthcare that is deliverable and where needed.”

Even now, residents of Eight Ash Green and Aldham do not have access to high quality healthcare, with GP surgeries, which are some distance away, being overwhelmed. Addition of 250 households with no additional medical capacity or facilities obviously would make access to healthcare worse both for existing residents and prospective new residents.

• “Create communities which reduce the need to travel, particularly by car for most of their daily needs.”

To the contrary, development at this site clearly would increase the need to travel, particularly by car, for residents of the proposed new development, for all of their daily needs.

h. It is said in relation to policy ST1 (Health and Wellbeing) that “Developments which will have an unacceptable significant adverse impact on health and wellbeing which cannot be mitigated, or that fail to offer reasonable provisions, will not be permitted.”

The proposed development at this site will have an adverse impact on health and wellbeing of existing residents, who will lose enjoyment of a green open space surrounding a public footpath, and will face further encroachment on to their rural way of life. No provisions in respect of improvement of health are offered however.

i. It is said under Policy ST2 that “The Council will safeguard the landscape character of Colchester.”

By proposing this site for development of dwellings, the Council are doing the opposite, and abdicating their responsibilities in this respect, which is impermissible. The Counsel seem to be advocating destruction of an iconic view and of the rural character of the area.

j. Paragraph 3.7 says “The purpose of this strategic policy is to ensure that all proposals conserve and enhance the natural and historic environment and that major residential proposals deliver contextually responsive, high quality open spaces. The key purpose of this strategic policy and indeed all policies in the Environment chapter, is to respond to the creating a better environment agenda by halting overall biodiversity loss,”

The proposal for development at this site is directly contrary to these requirements. It would involve destruction of the environment in the area in question, and notwithstanding that consultants hired by the promoter/developer might try to argue to the contrary, it is obvious as a matter of common sense that there will be loss of biodiversity, and not a gain, by concreting over green farmland which contains hedges and trees and numerous species of animals with freedom to roam in favour of dwellings.

k. Paragraph 3.18 talks in the last sentence of “the importance of the countryside that should be protected.”

l. Paragraph 3.23 says that “The settlement hierarchy identifies medium and small settlements where growth is allocated appropriate to the size of the settlement and its constraints.” As set out above, Eight Green has wrongly been categorised for this purpose as a medium settlement, and the proposed development at PP32 is not appropriate in size to the settlements or Aldham or Eight Ash Green and their constraints.

m. In relation to Policy ST3: Spatial Strategy, in a sub-paragraph of paragraph 3.25 it is said that:

i. “The highest areas of sensitivity are receiving the lowest levels of growth in this Local Plan.”

The proposed development of the PP32 site, which is a beautiful rural area, with 250 dwellings, is directly inconsistent with this principle.

ii. “This approach also ensures that existing settlements maintain their distinctive character and role by avoiding harmful coalescence between them and through conserving their setting.”

The proposed development of the PP32 site, and also the PP31 site, would have the effect of building on vital green gap areas, and joining Eight Ash Green with Aldham, and Eight Ash Green with Colchester, creating an unbroken corridor of housing for miles on Halstead Road, turning Eight Ash Green and Aldham into suburbs of Colchester. The residents in the villages of Eight Ash Green and Aldham chose to live in those places because they are villages and because of their rural character, and not in unbroken built-up suburbs of Colchester.

The proposed development of the PP32 site would destroy its setting of openness and wonderful views over a rolling valley.

n. The proposed development is contrary to all of the following principles which are set out at paragraphs 3.26 – 3.31:

i. “The Strategy must provide for social and economic needs, sufficient strategic and local infrastructure, whilst balancing the conservation and enhancement of the natural … environment, and address climate change, mitigation and adaptation.”

ii. The preferred spatial strategy draws together the positives from as many of the spatial options as possible, while ensuring the growth needs of Colchester are met. These include:

• Ensure protection and enhancement of the most sensitive environments

iii. This will be balanced against ensuring development does not have an adverse impact on the different roles and relationships between settlements and their separate identities, valued landscapes, the intrinsic character and beauty of the countryside and visual amenity.

iv. The intrinsic character and beauty of the countryside will be recognised and assessed, and development will only be permitted where it would not adversely affect the intrinsic character and beauty of the countryside.

v. Proposals must consider the role the landscape plays as an open buffer between settlements or areas of a settlement, and the resulting sense of separation and distinctive identity.

vi. Where residential proposals are located outside defined settlement boundaries, there should be consideration of the physical and functional connection to the defined settlement in the first instance. Residential proposals in the countryside should conserve and enhance the character, quality and tranquillity of the landscape, and it must be proven that they will protect and reinforce the rural character of the areas where a development is proposed. … Opportunities to maximise access to sustainable modes of travel for future residents must be demonstrated.

vii. The NPPF recognises that there are three dimensions to sustainable development: economic, social and environmental. Settlement boundaries are an essential tool for the management of development and contribute to the achievement of sustainable development by preventing the encroachment of development into the countryside, protecting rural character.

viii. It is essential that development is restricted in the countryside to protect landscape, character, quality and tranquillity.

o. The proposed development at the PP32 site is also contrary to the requirement under Policy ST7 which is set out at paragraph 3.60 that “All development must be supported by the provision of infrastructure, services and facilities that are identified as being needed to serve the needs arising from the development. Permission will only be granted if it can be demonstrated that there is sufficient and appropriate infrastructure capacity to support the development or that such capacity will be delivered by the proposal.”

There clearly is not sufficient and appropriate infrastructure capacity in any respect to support development at this site. All that is being suggested is a new bus stop, which is risible from the Planning Team, who seem to be unconcerned, or oblivious, about even greater overloading of stretched services, and at the prospect of the social and environmental consequences arising out of a big development in an isolated location with inadequate services.

p. In addition the proposed development at the PP32 site would infringe the principles set out in the “Environment” section of the Local Plan at paragraphs 4.1 – 4.4:

i. “Colchester's countryside … is extremely … important in terms of its natural and historic environment, including biodiversity, landscape character ... The natural environment contributes to what is unique and special about Colchester. The countryside provides the attractive landscape setting that defines and characterises the villages and rural communities of Colchester.

ii. “These policies will contribute towards the theme in the vision of healthy, vibrant and diverse places … protecting stretches of undeveloped countryside …”

iii. “The policy recognises and reflects the hierarchy of sites in accordance with the NPPF, which states that planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes …”

q. Policy EN3: Biodiversity and Geodiversity at paragraph 4.13 says “Proposals for development that would cause significant direct or indirect adverse harm to nationally designated sites or other designated areas, protected species, Habitats and Species of Principal Importance and local importance, will not be permitted …”

Badgers, at least, are present at the PP32 site.

r. Paragraph 6.1 says: “This chapter on Landscape and Coast outlines the importance of preserving and enhancing the natural environment, focusing on the landscapes … that play a pivotal role in Colchester's ecological heritage and the wellbeing of our residents. These spaces not only provide vital habitats for wildlife and support biodiversity, but also serve as areas for recreation, relaxation, and connection with nature. By safeguarding these areas, we aim to maintain a balanced relationship between development and environmental stewardship, ensuring that Colchester's landscapes … continue to enrich the lives of current and future generations …”.

These principles seem wrongly to have been ignored when proposing site PP32 for development.

s. The correct position as regards avoiding new dwellings in the countryside is illustrated by paragraph 8.35, which appears to have been disregarded when proposing site PP32: “The NPPF states that one of the few circumstances where a new dwelling within the countryside may be justified is where there is an essential need for a rural worker to live permanently at or near their place of work in the countryside.”

t. Policy PC2: Active and Sustainable Travel, at paragraph 11.8 sets out requirements for new developments which are not met in relation to the proposed development of 250 dwellings at site PP32:

Proposals for development should:

(a) Give priority to the movement of people walking and cycling;

(g) Facilitate access to high quality public transport infrastructure; and

As set out above, the nearest concentration of shops is 3.5km away, and the centre of Colchester is 8.5km away. Most people cannot, or will not, walk or cycle such distances, and certainly cannot do so whilst transporting shopping. This development is in an isolated location which would be totally car reliant. Elderly people and/or people with restricted mobility would be in a very difficult situation in a development at this location, as would anyone who does not have a car.

11. The PP32 and PP31 sites really are green belt land, maintaining gaps between small settlements, and from urban sprawl of Colchester. Paragraph 142 of the NPPF is instructive as regards the importance of preventing development on such land:

142. The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

143. Green Belt serves 5 purposes:

(a) to check the unrestricted sprawl of large built-up areas;

(b) to prevent neighbouring towns merging into one another;

(c) to assist in safeguarding the countryside from encroachment …

In Aldham Parish so can EAG have influence on this site? Living on Halstead road currently significant dangers to pedestrians and cyclists due to current traffic volumes. Access to and from development will make this worse. increased traffic along the A1124 which is already very busy and difficult to cross on foot or exit ones drive. General pressure on infrastructure seems not to be considered.

Objection to Draft Policy PP31 and PP32 in favour of sites proposed by Eight Ash Green Parish Council:

I have separately commented on the planning application that has been made for site PP32, which is inappropriate for many reasons: ribbon development, outside village envelope (actually part of Aldham Parish), car dependent, landscape and bio-diversity damage, lack of accompanying infrastructure/amenities etc.

Many of these issues apply wherever in Eight Ash Green (EAG) is chosen for development - not to mention that the village has just had 150 homes built by Bellway in the last two years which has increased the number of houses in the village by 19% (from 800 to 950). Now it is proposed to add another 410 houses, which is a further increase of 43% (a net 70% increase in the number of houses since the EAG Neighbourhood plan was agreed in 2019!)

If the village has to accept development then the more appropriate sites would be those suggested by the Parish Council as an alternative - which would encounter significantly less local opposition. These alternative sites are less damaging to the landscape and views (especially compared to PP32) and to the general rural aspect. They are also more central within the village, rather than further ribbon development far from the limited existing facilities, which was explicitly rejected in 2019 in the agreed Neighbourhood Plan.

These alternative more centralised locations are more likely to foster a sense of community and increase the possibility of private businesses setting up to benefit the residents (eg local shop, pub, doctors). They would allow for more use of public transport and reduce the need for cars (congestion already being a problem).

The fact that both alternative sites are on the south side of the A1124 Halstead Road is not a sufficient barrier to development there as the additional benefits of centralisation and reduction in harms to the landscape outweigh the downside of housing on both sides of the main road. Multiple pedestrian crossings can be always be added.

Despite my clear view that any further development in Eight Ash Green is damaging, having already accepted a significant development (Bellway), I do support the Parish Council’s suggested alternative sites over development of PP31/PP32.

I prefer pp32 over the other sites. I do not like the site on blind line or pp31. The road will be impossible to get out of and it will ruin the lane. There is not enough parking or buses.

This is an area that does not have the infrastructure to support this many new homes. There are poor transport links and road traffic at bust times is incredibly busy. It is a single lane carriageway each way. There is also no shopping for food or similar at all, which will drive more people towards the already incredibly overcrowded tollgate and stand retail parks, making traffic worse in the surrounding areas.

Although it says the forrest will be not be built on, all the additional housing, people, infrastructure will put a great strain on the environment here and have a severely negative affect on the biodiversity of the area which currently is thriving. We should be protecting these areas of natural beauty in Essex not boxing them in and removing them from view.

It will also ruin beautiful views across our lovely green space countryside from the road, and increasing urban sprawl rather than looking at brown field sites or other already much more built up areas in the city which could be added to.

Concerns for the ancient woodland on plan PP32, presently the watercourse falls in to the ancient woodland and during wetter months a holding pond is filled which gradually leaks into the ancient woodland. It appears from the plans that the watercourse falls will be diverted off the site in to another area, and biodiversity mitigation buffer to the watercourse to protect the woodland has not been considered.
Concerns that the present footpath that goes through the woodland heading on to Fiddlers Hill, has no pavement and vehicles from skip Lorries, HGVs, tractors and cars use this route, potentially people are being guided by the footpath to a bus road, where as this footpath could be diverted up the field to Aspen way.
Two additional sites have been proposed, south of the Halsted Road, which I believe are better suited to the village, and should be seriously considered. There could also be the possibility of adding a roundabout on the Halsted Road out of one of the areas and Aspen walk, to what will become a very busy road.

I wish to object to PP32, for the following reasons:
It is placed outside of the village, in fact in Aldham and will then result in harder to control future planning if no boundaries are deemed as valid.
Eight Ash Green will become a ribbon development, making it extended with few amenities in walking distance, resulting in more car journeys. Stane Park the nearest retail development is inaccessible by foot, already overcrowded and because of poor parking and planning it becomes gridlocked frequently with entry and exit times over the hour.
There is no sustainable infrastructure in place, the area needs proper planning, rather than just build houses. There was a clear indication that Highways improvements are needed, with great expense and consultations being carried out, showing the A12 improvements are needed to support any further developments. However with the cancellation of these improvement to the A12, consideration must be given for all proposed developments. Roads are unsuitable at present.
In the previous call for sites EAG was consulted properly, resulting in actual residents who knew the area and conditions, being able to identify and vote for the most acceptable and practical sites to be used, rather than a remote decision by outside influences, who have no practical knowledge or even skill.Hence Aspen Walk was voted and chosen by the majority of EAG. Concerns are raised that this is still to be adopted by Highways due to poor legislation, which unfairly places the burden on residents to likely be financially responsible for publicly used highways, will this be the same for PP32?
My biggest concern with PP32, is the negative impact it will have on the Ancient woodland that is adjoins. Proper consideration needs to be given to the adverse hydrological impact that will occur to the wood, that has a holding pond and ditches to facilitate life. This being taken away from the wood will have a detrimental affect resulting in the loss of rare woodland, flora and wildlife. I am aware that experts have considered suds areas without thought to what and where the current hydrology actually feeds. I am also aware that The Woodland Trust objected to a single replacement dwelling, near the proposed site, stating the additional footfall in the ancient woodland would have a detrimental affect . Note this was refused for a single 2 bed dwelling not 250 houses!
Once the woodland is harmed it is too late and will take years to replace.
If local opinion counts then, I support the parish council’s proposed developments, which are in a better position to reduce the ribbon development and maintain at least a small chance of EAG remaining a village.
The village hall fiasco, means that EAG is currently building an unsuitable village hall for the present size of the village . Consideration needs to be given for the increase in size and possibly a second village hall if this proposals go ahead, possibly resulting in an East and West Eight Ash Green .

There is valid concern of detrimental damage to the adjacent Ancient Woodland by means of deprivation of water runoff if there is more building here, particularly with the prospect of hotter & drier summers. There is also the very real prospect of unmonitored public encroachment of the wood which would impact on the wildlife there, which include deer and badger. The reference (j) to contribution to provision of a new village hall is confusing as there is one now under construction on the site off Spring Lane.

PP32 Aldham
Development in the countryside - this large development will adversely affect the beauty and character of our small village
There will be no open buffer between Eight Ash Green settlement and proposed development
A1124 and A12 junction already at capacity and cannot cope with existing traffic
Aldham has no footpaths to the village centre, no schools, shops, health or dentistry facilities to support this large development
Will have a negative effect on farming/food production favouring profiteering of landowners who should be encouraged to contribute to Food Security by farming the land not selling land for quick profits.

PP32 Aldham Development
Junction 26 is already at capacity and the road from Green labe to Marks Tey are already in poor condition before you add another 2000 cars. You blight Aldham with pylons then kick us in the teeth with housing. You have completely disregarded this community and the people that live here

I support this as there is Alignment with the Settlement Boundary and Preferred Development Area The Neighbourhood Plan defines a clear Village Settlement Boundary (Policy VSB 1) that includes areas north of A1124 (incorporating sites like the original Fiddlers Field allocation) but explicitly excludes land south of A1124 (areas around Seven Star Green). Development proposals must respect this boundary, with a general presumption against building outside it unless exceptional circumstances apply. PP31 and PP32 sit north of the A1124, making them compatible with this boundary and the Plan's focus on consolidating growth around existing Eight Ash Green village cores.

Prevention of Coalescence and Maintenance of Separation from Neighboring Settlements The Plan's Vision (p. 11) and Policy EP1 (Coalescence, p. 39) emphasize keeping Eight Ash Green as a distinct rural village, clearly separated from Stanway, Colchester, and the proposed West Tey Garden Community/New Town. Development south of the A1124 risks narrowing or eliminating these physical and visual gaps, leading to urban sprawl and loss of countryside separation. PP31 and PP32, being north of the road, avoid this risk entirely and help reinforce the village's standalone identity.

Strong Community Preference and Evidence Base The Neighbourhood Plan reflects overwhelming community support (90%+ in consultations) for limited, integrated growth in one or a few well-chosen northern sites rather than dispersed or southern expansion. Residents prioritized avoiding sprawl, ribbon development, and southern extensions that would alter the village's rural character. PP31 and PP32 build on this by focusing growth in a sustainable medium settlement with existing services (primary school, shop, petrol station, village hall).

Having considered the plans for additional housing in Eight Ash Green, I would support the use of the sites PP31 and PP32 as suggested by the Colchester City Council

I am writing to object to the alternative sites being proposed for development in Eight Ash Green. Currently in the village plan seven star green has been removed from the village settlement as being unsustainable as it is located south of the Halstead Road. A previous planning application for a single dwelling in seven star green was rejected on this grounds and yet now there is the prospect of building hundreds of houses.
Thank you for your time
Nicole Hurst

As a resident of Fordham Heath for the past 29 years, I am writing to object to the proposed inclusion of sites PP31 and PP32 in Colchester’s draft Local Plan
.I believe they would: Give rise to an undesirable ribbon development for Eight Ash Green and Fordham Heath, and link them, through PP32, with neighbouring Aldham. The result would also be housing concentrated entirely on the north side of the A1124, giving a very unbalanced appearance;
Add even more vehicular pressure on the A1124, which is already extremely busy, carrying traffic into and out of Colchester. It is nigh-on impossible to walk along the abutting pavement which is narrow and overgrown. Pedestrians are forced to share any available pavement with cyclists fearful of using the A1124;
The developers behind PP32 seem to have “jumped the gun” on the forthcoming Local Plan by submitting their application early, seemingly attempting to preempt the LP consultation process;

The two-acre plot, separate to, but apparently part of PP31, is on a A1124 double bend which has seen its more than its fair share of accidents over the years, where vehicles have ended up in the adjacent ditch. The bends also mean that the A1124 vehicular access and egress from/onto the site would extremely difficult and narrow, if not impossible. I would request that, should PP31 be included in the local plan, the extant watercourse on the northern boundary, which has linked two ponds in the village for many years, be retained.
I am aware of other possible housing sites in the village which I believe would be more suitable than PP31 and PP32, being on the south side of the A1124 and creating, should they be developed, a more aesthetically pleasing and centred look to Eight Ash Green. If chosen over the two preferred options, there would be no ribbon development and no link-up with Aldham. The impact on the A1124 would remain, however.
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Speaking generally, residents here and across the borough are extremely concerned that the unprecedented increase in housing imposed on Colchester and its villages comes without a single thought for the undoubted impact on - and the future of - primary and secondary schools, GP and dental surgeries, Colchester General Hospital and other vital services.

I am writing to formally object to the draft policy proposing new housing development in Eight Ash Green.
While I recognise the need to address housing demand within Colchester, I do not believe that the scale and location of development proposed for Eight Ash Green is appropriate, sustainable, or justified, for the reasons set out below.
1. Unsustainable Location and Lack of Infrastructure
Eight Ash Green is a small rural village with limited local services and facilities. There is no secondary school, limited access to healthcare, and very restricted local employment opportunities. As a result, any significant new housing would be heavily car-dependent, contrary to national and local planning objectives which seek to reduce reliance on private vehicles and promote sustainable development.
2. Highway Safety and Traffic Impact
The existing road network serving Eight Ash Green is already under pressure, particularly at peak times. Local roads are narrow, rural in character, and not designed to accommodate a substantial increase in traffic. The draft policy fails to adequately demonstrate how additional traffic generated by new housing would be safely accommodated without harm to highway safety or severe congestion.
3. Pressure on Existing Services
Existing infrastructure, including primary school capacity, drainage, healthcare provision, and public transport, is already limited. The draft policy does not provide sufficient evidence that the necessary infrastructure improvements would be delivered in a timely manner to support new development, risking a decline in quality of life for both existing and future residents.
4. Harm to Rural Character and Settlement Identity
Eight Ash Green has a distinct rural character and a clear settlement boundary. The proposed housing growth risks disproportionate expansion that would erode the village’s identity, harm its setting, and potentially lead to coalescence with nearby settlements. This would be contrary to policies aimed at protecting the character of rural communities.
5. Lack of Robust Evidence and Justification
The draft policy does not clearly demonstrate why Eight Ash Green has been selected for further housing growth over more sustainable locations with better access to services, employment, and public transport. Without robust evidence, the proposal appears unjustified and inconsistent with the principles of plan-led development.
Conclusion
For the reasons outlined above, I consider the draft policy for new housing in Eight Ash Green to be unsound, unsustainable, and contrary to both national and local planning objectives. I respectfully request that the Council reconsider this proposal and remove or significantly revise the policy to better reflect the constraints and character of Eight Ash Green.
Yours faithfully,
Yvonne & John Robinson

We are opposed to the planned sites for extra housing on these sites PP32/PO32
On many issues.
Lack of public transport along Halstead Road linking Stane Park Tollgate and Colchester city centre.
Lack of existing pedestrian walkway linking stane Park being upgraded.
Lack of any infrastructure
Danger of merging traffic onto Halstead road.
Possibility Flooding on site PO32
Eight ash green will loose its village status and become ribbon development along Halstead road which is already gridlocked with traffic

Sites preferred by Parish Council if there has to be housing are preferred by us too.
Developers are already engaging with the parish council and listening to concerns of existing residents. Flexible in their approach.
The Proposed sites south of Halstead road are preferred by Parish Council not the sites proposed by council.

We therefore propose the sites south of Halstead road if housing is inevitable in eight ash Green.

We are opposed to the planned sites for extra housing on these sites PP32/PO32
On many issues.
Lack of public transport along Halstead Road linking Stane Park Tollgate and Colchester city centre.
Lack of existing pedestrian walkway linking stane Park being upgraded.
Lack of any infrastructure
Danger of merging traffic onto Halstead road.
Possibility Flooding on site PO32
Eight ash green will loose its village status and become ribbon development along Halstead road which is already gridlocked with traffic

Sites preferred by Parish Council if there has to be housing are preferred by us too.
Developers are already engaging with the parish council and listening to concerns of existing residents. Flexible in their approach.
The Proposed sites south of Halstead road are preferred by Parish Council not the sites proposed by council.

We therefore propose the sites south of Halstead road if housing is inevitable in eight ash Green.

As per attachment:
1. Introduction and Scope of Representation
This comprehensive planning representation is submitted in response to the Colchester City
Council Preferred Options Local Plan (Regulation 18) consultation. It specifically addresses
the proposed spatial strategy for the settlement of Eight Ash Green, with particular reference
to the proliferation of allocated and alternative development sites threatening to encircle the
property known as Starcrest, situated on Seven Star Green.
The representation is formulated to support the Council’s specific spatial strategy (allocating
Policies PP31 and PP32 to the north) while demonstrating that the inclusion of any "Alternative
Sites" proposed to the south of the A1124—specifically Site 10264—would be unsound,
legally non-compliant, and in direct conflict with the adopted Development Plan, most notably
the Eight Ash Green Neighbourhood Plan (2019).
1.1 The Locus Standi of the Objector
The objection is brought forward by the residents of Starcrest, a substantive
multi-generational dwelling located within the historic hamlet of Seven Star Green. The
property is situated in a highly sensitive semi-rural interface, bordered by the A1124 Halstead
Road to the north and open countryside to the south. The location is characterized by its
detachment from the main village settlement, a characteristic formally recognized in the
"made" Neighbourhood Plan which actively removed this area from the settlement boundary
to preserve its rural integrity.
The promotion of "Alternative Sites" seeks to fundamentally alter this context by allocating
land for residential use immediately "behind" (south/adjacent) the objector’s property. When
viewed alongside the preferred allocations "in front" (north), the cumulative effect would be
the total encirclement of Starcrest and Seven Star Green by urban development, transforming
a historic rural hamlet into an enclosed suburban enclave. This represents a material change
in the living conditions of the residents and a degradation of the local environment that was
explicitly protected by the democratic vote of the village in 2019.
Executive Summary of Position:
The objectors wish to place on record a qualified endorsement of the Council’s specific
spatial strategy for Eight Ash Green, insofar as it correctly directs necessary growth to the
least sensitive locations north of the A1124 (Policies PP31 and PP32) and categorically
excludes the allocation of land south of the A1124.
Consequently, this submission serves two primary functions:
1. To support the soundness of the Council's decision to utilize the A1124 as a definitive
defensible boundary, aligning with the "Plan-Led" approach mandated by Section 38(6)
of the Planning and Compulsory Purchase Act 2004.
2. To formally object to the inclusion of any "Alternative Sites" in the southern sector,
providing evidence that such allocations would be unsound, legally non-compliant with
the December 2024 NPPF, and contrary to the adopted Development Plan.
2. Procedural Objection: Violation of Gunning
Principles & Local Democracy
Prior to addressing the spatial merits, objection is raised regarding the timing and conduct of
this Regulation 18 consultation (26 Nov 2025 – 14 Jan 2026) and the failure of local
democratic representation.
2.1 The "Gunning Principles" (Fair Consultation)
It is a fundamental principle of public law, established in R v London Borough of Brent ex parte
Gunning, that consultation must be fair. The third Gunning Principle requires that "adequate
time must be given for consideration and response." Conducting a strategic consultation
heavily overlapping with the statutory Christmas and New Year holidays effectively removed
10-14 days of "working time" for residents to seek professional advice. This timing prejudices
lay stakeholders compared to professional land promoters who have resources to monitor
such consultations year-round.
2.2 Failure of Parish Council Representation
We further note with concern the conduct of the Parish Council meeting convened days
before the deadline. While the individual Councillors were courteous, the decision-making
process appears procedurally and technically flawed:
● Flawed Assessment Criteria: It was observed that the Parish Council’s apparent
support for "Alternative Sites" was predicated on a subjective assessment of "fewer
immediate neighbours affected" (a utilitarian headcount) rather than a robust objective
assessment of material planning constraints. Planning law requires sites to be assessed
on their technical merits (e.g., Heritage impact, Flood risk, Highway safety). Prioritizing
sites simply because they are less visible to the majority, while ignoring critical
constraints such as the impact on the Registered Village Green, protected Schedule 1
Species, and Highway Safety, constitutes a misapplication of the planning balance and
fails the test of soundness.
● Lack of Mandate: Any representation made by the Parish Council that deviates from the
adopted Neighbourhood Plan has been determined without meaningful public
engagement or a village-wide mandate. There has been no village survey, no referendum,
and no public exhibition regarding this specific shift in policy.
● Conflict with Neighbourhood Plan: If the Parish Council has signaled support for sites
south of the A1124, this stands in direct contradiction to their own "made" Policy VSB1
(which excludes this land). As there has been no subsequent referendum to authorize
this U-turn, such representations should be disregarded by the Inspector as they do not
reflect the legally adopted will of the community.
3. The Planning Case for the Exclusion of Southern
Sites
The exclusion of land south of the A1124 is not merely a preference; it is the only legally robust
position available to the Council.
3.1 Primacy of the Development Plan (NP & VDS)
The Eight Ash Green Neighbourhood Plan (EAGNP) was "made" in December 2019 and
remains part of the statutory Development Plan.
● Policy VSB1 (Village Settlement Boundary): The EAGNP explicitly redrew the boundary
to exclude Seven Star Green and the land south of the A1124. This was a deliberate
policy intervention to protect the rural character of the southern hamlet. This boundary
was not arbitrary; it was the result of extensive landscape analysis and community
consultation which confirmed the south side's unsuitability for growth.
● Village Design Statement (VDS): The adopted VDS identifies Seven Star Green as a
distinct "hamlet" typology that must be preserved from coalescence. Allocating the
"Alternative Sites" would breach the design codes set out in this supplementary planning
document, specifically those requiring the maintenance of the loose-knit rural grain that
defines the settlement edge.
● NPPF Paragraph 30: Confirms that once a neighbourhood plan is in force, its policies
take precedence. There is no "clear and convincing" justification provided by any party to
override the community's recent spatial strategy, particularly when sufficient land is
available elsewhere (Policies PP31/PP32).
3.2 The Sustainability Appraisal: Severance and Highway Safety
We endorse the Council’s Sustainability Appraisal (SA) (2025), which states: "Seven Star
Green is not considered sustainable as it is located south of Halstead Road...". This finding is
supported by critical safety deficits:
● Active Travel England (ATE) "Critical Fail": ATE standing advice (2024) requires
footways to be a minimum of 2.0m wide for safe use. The southern frontage of the
A1124 (adjacent to the "Alternative Sites") possesses no continuous footway. Residents
would be forced to walk in the live carriageway or cross the 40mph strategic road to
access the northern pavement. Retrofitting a compliant footway here is physically
impossible without third-party land acquisition or narrowing the A1124, which would be
unacceptable to the Highway Authority.
● The School Run - Risk to Vulnerable Users: Allocating family housing to the South
would necessitate children crossing this busy 40mph strategic road to access Holy Trinity
Primary School. There are no controlled crossings (Zebra, Pelican, or Puffin) on this
stretch of road. This hazardous environment effectively removes the option of walking
to school for new families, forcing reliance on private cars. This directly contradicts NPPF
Paragraph 114, which mandates that development must prioritize pedestrian and cycle
movements and facilitate access to high-quality public transport.
● Unresolvable Conflict: To fix this, a developer would need to install new signalized
crossings. However, given the traffic volumes on the A1124, the introduction of traffic
lights or zebra crossings would severely disrupt the flow of this strategic distributor route,
causing unacceptable congestion, "stop-start" delays, and air quality issues. The site is
therefore trapped in a planning failure: it is unsafe for pedestrians without crossings, but
damaging to the highway network with them.
3.3 Strategic Land Availability Assessment (SLAA) Confirmation
We note that the Council’s own technical officers have assessed the southern land (Site
10264) within the SLAA and graded it Red/Amber (Discounted). The specific reasoning—that
the site is "detached from the two main settlement areas"—is sound. We urge the Inspector to
uphold this technical assessment against developer pressure, as nothing has changed
physically on the ground to warrant an upgrade of this assessment.
4. Technical Constraints of the "Alternative Sites"
The specific land parcels promoting themselves as "Alternative Sites" south of the A1124
suffer from acute constraints that do not apply to the northern allocations.
4.1 Landscape Character: "Farmland Plateau"
The Colchester Borough Landscape Character Assessment (CBLCA) identifies this area as
Type B: Farmland Plateau.
● Key Characteristics: This character type is defined by open, elevated arable fields with
long views and a sensitivity to built form. It is distinct from the enclosed landscape to the
north of the village. The openness of these fields is integral to the setting of the hamlet.
● Policy ENV1 (Environment): Local Plan Policy ENV1 requires development to "conserve
and enhance" landscape character. The "Alternative Sites" would introduce high-density
suburban form into a landscape defined by its openness and rurality. This would result in
a jarring visual intrusion that fails to respect the established character type.
● Visual Impact: Unlike the enclosed sites to the North, the Southern sites are visually
prominent from multiple viewpoints. Development here would degrade the "rural edge"
transition that defines the entry to the village, replacing the soft green buffer with a hard
urban edge.
4.2 Heritage Impact: The "Encirclement" of VG188
Seven Star Green is a Registered Village Green (VG188). Its significance is defined not just
by the grass, but by its open agrarian setting.
● Encirclement: The "Alternative Sites" propose development on the fields immediately
behind Starcrest and the Green. This would encircle the Green with modern housing,
transforming a historic rural common into a suburban amenity space. The loss of the
connection between the Green and the wider countryside would fundamentally harm its
heritage significance.
● NPPF Paragraph 215 (Zero Benefit Test): The December 2024 NPPF states that where
development leads to "less than substantial harm" to a heritage asset, it must be
weighed against public benefits.
○ The Test: As the Council can already demonstrate a robust housing supply through
Policies PP31/PP32 (North), there is zero additional public benefit to allocating the
southern sites.
○ The Result: With no public benefit to outweigh the identified harm to the setting of
the Village Green and Listed Buildings, the presumption must be to refuse allocation.
4.3 Hydrogeological and Drainage Constraints
● Geology: The underlying geology is Glacial Sand and Gravel over London Clay. This
specific stratification presents severe drainage challenges.
● SuDS Hierarchy Failure: The "SuDS Hierarchy" requires infiltration (soakaways) as the
priority solution. However, the heavy clay subsoil in this specific location renders
infiltration ineffective. The ground simply cannot absorb the volume of runoff generated
by a new housing estate.
● Local Evidence: Residents of Starcrest currently experience significant surface water
retention ("bogginess") in gardens for extended periods during the winter. Replacing the
remaining absorbing farmland with impermeable hardstanding (roads and roofs) would
inevitably displace this surface water onto lower-lying residential curtilages. The site
cannot support a sustainable drainage strategy without pumping or massive attenuation,
which raises significant viability and long-term maintenance concerns.
4.4 Ecological Constraints: Protected Species & Functional Linkage
● Bats (Various Spp.): Residents of Starcrest witness significant bat activity nightly within
the curtilage of the property and the adjacent fields. The hedgerows and tree belts
bordering the "Alternative Sites" provide essential foraging corridors. Development would
sever these corridors and introduce lighting that disrupts flight paths, constituting an
offence under the Conservation of Habitats and Species Regulations 2017.
● Red Kites (Milvus milvus): It is noted that Red Kites (Schedule 1, Wildlife and
Countryside Act 1981) are nesting in the immediate vicinity. These birds are highly
sensitive to disturbance during the breeding season.
● Functional Linkage: The open fields of the "Alternative Sites" are not just empty space;
they provide the essential hunting ground ("Functional Linkage") for these species. Loss
of this foraging habitat would result in a net decline in biodiversity, failing the
Environment Act 2021 requirements for Biodiversity Net Gain.
4.5 Impact on Dark Skies and Rural Character
The hamlet of Seven Star Green is currently characterized by dark skies at night, consistent
with its rural setting.
● Light Pollution: The introduction of a housing estate would necessitate street lighting,
security lighting, and vehicle headlights. This would introduce artificial light into an area
that has historically remained dark.
● Harm: This would fundamentally alter the character of the hamlet from "rural" to
"suburban" and cause significant disturbance to the nocturnal wildlife (specifically bats)
identified in Section 4.4. This contravenes the NPPF requirement to limit the impact of
light pollution on intrinsically dark landscapes and nature conservation.
4.6 Agricultural Land Classification and Food Security
● Grade 2 Land: The land south of the A1124 is mapped as Grade 2 (Very Good)
Agricultural Land. This is a finite national resource.
● NPPF Paragraph 181 (Dec 2024): The revised Framework explicitly emphasizes "food
security" and the economic benefits of Best and Most Versatile (BMV) agricultural land. It
directs planning authorities to prioritize poorer quality land for development.
● Sequential Test: The Council is right to prioritize the fragmented land to the North (infill
between village and A12), which has lower agricultural utility, over the high-quality,
continuous productive arable land to the South.
4.7 Utilities Infrastructure: Proven Capacity Deficits
Paragraph 8 of the NPPF requires the provision of accessible local services.
● Existing Deficiency: The local water supply network is operating at hydraulic limits, with
residents experiencing notable pressure fluctuations during peak times. This indicates a
network under stress.
● Constraint: Adding significant housing load to this fragile spur without guaranteed,
pre-commencement reinforcement constitutes a direct threat to residential amenity. It is
unacceptable to degrade the service to existing residents to facilitate speculative
development.
5. Conclusion and Formal Request
The residents of Starcrest support the Council's pragmatic approach in the Preferred Options
Local Plan. The northern sites (PP31/PP32) represent a logical "Grey Belt" style prioritization
of sustainable infill.
Conversely, the "Alternative Sites" south of the A1124 are legally obstructed by the
Neighbourhood Plan, ecologically sensitive, and severed from the village.
The "Precedent" Danger:
We caution the Council that the A1124 acts as the only logical defensible boundary for the
settlement. Permitting any development south of this road (at Seven Star Green) would set an
irreversible precedent, effectively unlocking the entire southern arable landscape for sprawl
and destroying the distinct character of the hamlet.
We formally request that:
1. The Council maintains its rejection of Site 10264 and all "Alternative" sites south of the
A1124.
2. The Settlement Boundary defined in the Eight Ash Green Neighbourhood Plan (Policy
VSB1) is upheld as the permanent limit of development.
3. The Procedural Objection regarding the Gunning Principles and consultation timing be
recorded.
This document constitutes a formal representation under Regulation 18 of the Town and
Country Planning (Local Planning) (England) Regulations 2012.