ancient-woodland planning biodiversity hs2 land-use research-gaps

Ancient Woodland: England Stopped Publishing What It Loses

Asked for ancient woodland loss since 2010, government answered with an England figure for 2006 to 2015. The only measured, dated loss since 2010 in the record we read is HS2’s 17.66 hectares.

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In February 2023 a member of the House of Lords asked the government what estimate it had made of “the (1) loss annually since 2010, and (2) expected loss by 2030, of (a) woodland, and (b) ancient woodland”.

The Defra minister’s answer gave statistics for all woodland covering “the period 2012-2020”. For ancient woodland it gave one figure: “in England the level of permanent ancient woodland loss to other land uses was 57 hectares or 0.02% between 2006-2015”. It contains no ancient woodland figure for any period after 2015.

That is the story: not a number, but the absence of one. The last national figure government has given for ancient woodland loss ends in 2015, and nothing in the sources we read has replaced it. England defines ancient woodland as an irreplaceable habitat, writes its protection into planning policy and statute, and publishes no series showing how much of it is lost.

The only measured, dated loss of English ancient woodland since 2010 in the sources we read is HS2’s: 17.66 hectares on its first phase, London to the West Midlands, felled between January 2020 and December 2022, from HS2 Ltd’s own published data. It is public because an Act of Parliament, passed in 2021, requires the company to report it.

It is the only measured loss we found, not proof that no other ancient woodland was lost. A planning system that records losses one case at a time, in documents no one we found has added up, could hold far more or very little. No source we read can say which, and that is the finding.

What counts as ancient woodland, and how much England has

Government guidance defines it as “any area that’s been wooded continuously since at least 1600 AD”, and states that it “takes hundreds of years to establish and is defined as an irreplaceable habitat”. The test is a date on the map record, not the age of the trees: a replanted site still counts.

Natural England maps it in the Ancient Woodland Inventory. Queried directly on 26 September 2026, the inventory’s polygons summed to 364,970.81 hectares of England by their geometry, within one hectare of the layer’s own stated 364,971.81. On the 26 September reading it comes in two main kinds: ancient semi-natural woodland, 215,100.20 hectares, and plantations on ancient woodland sites, 149,732.77 hectares, which are ancient sites replanted with other trees and still counted.

The government’s 2022 policy statement, Keepers of Time, puts it in proportion: “ancient woodland in England makes up only 28% of all woodland”, against total woodland cover of “1.3 million hectares”. The inventory is known to be incomplete at the small end. The standing advice warns: “Ancient woodlands smaller than 2 hectares may not appear on these inventories.”

Why the inventory cannot measure loss

In 2017 a Defra minister told the Commons: “We monitor the protection of ancient woodlands through the ‘Ancient Woodland Inventory’.” The answer went on: “The Forestry Commission maintains the National Forest Inventory which monitors canopy cover change in woodlands, including ancient woodlands.” That survey can see change, but its only published estimate of ancient woodland loss covers 2006 to 2015 (more on it below).

The Ancient Woodland Inventory cannot do that job. It is a single current map, overwritten in place, and it has no date field of any kind. A wood removed from the map because it was drawn wrongly and a wood removed because it was bulldozed look exactly the same in it: absent, with no record of when or why.

It is also being redrawn, and the redrawing pushes the total up. Natural England’s revised inventory states that “small ancient woodlands (0.25-2ha) are being represented within the inventory for the first time”. It covers completed counties only, and on our query held 45,406 polygons and 212,549.22 hectares. Keepers of Time says “The updated inventory identifies more areas of ancient woodland in England”. A bigger total in a later year would therefore measure the mapping programme, not the land.

The totals also disagree with each other, and we could explain only some of the gaps. When we summed the original layer’s stored area field rather than its geometry, it came to 365,049.85 hectares, 79.03 hectares too high. Almost all of that is one wood: a 39.5 hectare plantation polygon called Monk Wood came with two tiny sliver polygons, each carrying the parent’s full stored area, so anyone summing that field counted it three times. That is a fault in a data field, not woodland. Natural England republished the layer on 29 September 2026. Re-read on 14 October 2026, the parts carried their own areas and the layer read 364,974.77 hectares over 53,640 polygons: two polygons and 3.96 hectares more than on 26 September, all of it ancient semi-natural woodland. Government’s 2022 policy figures give yet another sum. Their plantation figure, 149,733 hectares, matches the 26 September layer to within rounding, but their semi-natural figure, 215,156 hectares, is 55.80 hectares above it. Nothing we read explains the 3.96 hectares or the 55.80. Neither is evidence of loss, and a layer with no dates cannot rule loss out either.

Anyone who reports “the inventory shows X hectares lost” by subtracting one total from another is reporting a change in a map.

Government was asked, and said no

In January 2016 a Defra minister answered a Commons question directly: “we have no plans to collect data from Local Authorities on the loss of ancient woodland to development”. The reason given was that “The planning system records the loss of ancient woodland where development proposals require an Environmental Statement and these losses are then a matter of public record.”

We found no total of the losses recorded in Environmental Statements, and how many ancient woodland cases carry one at all we could not establish. A record that exists only case by case, scattered across planning files, is not a measurement of loss.

In 2022, Keepers of Time set an outcome: “By 2050 and beyond we will: maintain the existing area of ancient woodland”. The same document concedes: “we do not yet have sufficient data to measure all the ambitions we set out to achieve in this policy statement”.

Then came the 2023 Lords question about loss since 2010, and the answer about 2006 to 2015. The same 57 hectare sentence had been given in an earlier Lords answer in April 2021. Its source is the National Forest Inventory’s Preliminary estimates of the changes in canopy cover in British woodlands between 2006 and 2015, issued in August 2016. Its Table 19, “Actual and enhanced potential woodland loss on ancient woodland sites”, does give England a grand total of 57 hectares, 0.02%. Four cautions apply to it:

  • Only 2010 to 2015 of its period overlaps the question asked.
  • The 57 hectares is not all permanent loss, which is how the minister described it. In the table, 48 hectares are “woodland loss”; 4 are “ground under development”, which the report still counts as woodland area until the change is confirmed; and 5 are “newly established habitat”, cleared ground under other vegetation that becomes woodland loss only if it carries no canopy after 10 years.
  • It sees only what a satellite survey can: the report notes that its ancient woodland data “has a minimum size threshold of 2 hectares in England”, and that woodland loss “is only accounted for if greater than 0.5 hectare in extent”.
  • On Forest Research’s list of National Forest Inventory reports, read on 25 October 2026, it is still the only report on changes in canopy cover.

The survey has not stopped measuring loss. Forest Research’s Forestry Statistics 2026, released on 22 October 2026, gives England’s woodland loss for every year to 2024/25 from the National Forest Inventory’s maps: 197 hectares of “woodland loss” in the latest year, plus 145 hectares of ground under development, in categories that point back to the 2006 to 2015 report for their method. The Forestry Commission’s performance report for 2025-26 counts woodland lost to development each year to 2023-24 from the same survey. Neither splits out ancient woodland: the word does not appear in that loss table or its data, and the report’s only ancient woodland measure is restoration. The ancient woodland breakout the survey gave for 2006 to 2015 has not been published for any later year in the statistics we searched.

The one “since 2010” ancient woodland figure government does publish in these sources is a gain. Keepers of Time: “Over 27,000 hectares of plantations on ancient woodland sites in England have been brought into restoration since 2010.”

The one loss that was counted: HS2

HS2’s London to West Midlands section was authorised by the High Speed Rail (London - West Midlands) Act 2017. The later High Speed Rail (West Midlands - Crewe) Act 2021 added a duty at section 59: “The nominated undertaker must prepare and publish annual reports about the impact of the construction of each Phase of High Speed 2 on ancient woodland.”

To support the annual report that duty requires, HS2 Ltd publishes an open data layer of its ancient woodland impacts, last edited in November 2025. Queried directly, its as-built map holds:

  • Loss: 33 polygons, 17.66 hectares
  • Retained ancient woodland: 40 polygons, 21.91 hectares
  • Translocated ancient woodland soils: 58 polygons, 16.06 hectares
  • Compensation habitat: 87 polygons, 80.45 hectares

Of the 34 woods in its reporting layer, 25 have some current loss. The recorded felling dates run from January 2020 to December 2022, with 17 of those 25 woods worked in 2020 and 7 in 2021. On the page that hosts its strategies and reports, HS2 Ltd says the losses “currently reported should be considered a worst case figure which may be improved upon during the detailed design of the scheme”. That caveat looks forward to detailed design, so it reads as a caveat on the strategy-stage figures, not on the as-built 17.66 hectares.

The planning rule did not stop this, and was not built to. Since its February 2019 version, the National Planning Policy Framework’s exception for ancient woodland has given as an example “infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills)”, in words unchanged to December 2024 and still there in the August 2026 framework. HS2 was authorised by Act of Parliament in 2017, and its recorded felling began in January 2020. The Woodland Trust concedes the point: “Sadly, the NPPF changes will not protect precious sites from national infrastructure schemes like HS2.”

How “a third” became a revision

HS2 Ltd’s data gives its loss at the Environmental Statement stage as 26.6 hectares, and its loss now as 17.7. That is a reduction of 8.9 hectares, or 33.5%, and the Woodland Trust repeats it: “losses have been reduced by around a third”.

The layer records HS2 Ltd’s own reason for each change, and the reasons differ in kind:

HS2 Ltd’s stated reason Woods Net change
“Improvements in data accuracy in 2025 has reduced ancient woodland loss by …” 10 −5.6 ha
“Design refined in 2021 to reduce …” 10 −3.6 ha
“Additional … hectares required for clearance following design update” 2 +0.3 ha
Total 22 −8.9 ha

Design changes account for a net 3.3 hectares, about 12% of the baseline. Most of the reduction is a 2025 revision of recorded loss for woods that had already been worked.

The largest single case is Broadwells Wood in Warwickshire. Works ran April to June 2020. Its recorded loss was 3.2 hectares at baseline and is 1.4 hectares now, and the reason given in full is: “Improvements in data accuracy in 2025 and refinement of ancient woodland boundary has reduced loss by 1.8 hectares”. “Data accuracy” does not say which figure was wrong: whether the Environmental Statement over-forecast what was felled, or the map of the wood was redrawn. The annual report that might explain it is a PDF we have not read. Either way, a change made five years after the works is not avoided felling. These are figures for recorded loss.

The baseline has moved too. In January 2022 a Defra minister told the Commons that HS2 Ltd’s progress report “forecasts that 23.7ha of ancient woodland will be lost during construction of Phase One of HS2. This is a reduction of 5.7ha on what was expected in the Phase One Environmental Statement”. That implies a baseline of 29.4 hectares. The 2025 data gives 26.6. The same Environmental Statement is reported with two baselines 2.8 hectares apart, so any “percentage reduction” depends on which report it was taken from.

None of HS2 Ltd’s numbers is wrong on its own terms. But “HS2 cut its ancient woodland loss by a third” describes a change that was mostly made to the records, years after the felling.

The rule on paper, and the count we could not find

The planning protection was tightened once in this period. Government told the Lords in 2023 that “In 2018, the protection of ancient woodlands, ancient trees and veteran trees was strengthened through the National Planning Policy Framework”. From the February 2019 framework to the December 2024 one, the test read the same in every version we read, moving from paragraph 175(c) to 193(c) without a word changing:

“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”

The framework in force since 17 August 2026 keeps the test, lightly reworded, as policy N6(2): “Irrespective of a site’s status in nature conservation terms, development proposals which would entail 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.” Its footnote still names hybrid bills.

The same 2023 answer said that “In 2021, the Government committed to reviewing the NPPF with respect to ancient woodlands, consulting on strengthening the wording in the NPPF”. None of the versions we read changed the test’s operative words: refused “unless there are wholly exceptional reasons and a suitable compensation strategy exists”. What changed was referral: section 136 of the Levelling-up and Regeneration Act 2023 required the Secretary of State to extend the consultation direction to “applications for planning permission for development affecting ancient woodland”, and a revised Direction was published on 26 January 2024.

How many applications have been referred under it, and how many called in, we could not find. No written answer giving a count turned up in our search, which is a gap in the search as much as in the record.

One loose end makes the rule harder to follow than it should be. The standing advice, published 14 January 2022, still tells decision-makers to act “in line with paragraph 180 (c) of the NPPF”. That paragraph became 186(c) in December 2023, 193(c) in December 2024 and policy N6(2) in August 2026, so the reference is three versions out of date, and the page’s change history reads only “First published.”

What the campaigner counts

The Woodland Trust is a campaigning charity whose first stated aim is “protecting the UK’s rare, unique and irreplaceable ancient woodland”. It is also a landowner that “owns and cares for more than 1,000 woodland sites, covering around 33,000 hectares”, and it is helping to revise the inventory it campaigns with: a 2021 Lords answer records that “Natural England and the Woodland Trust have an active project to revise Natural England’s Ancient Woodland Inventory”. None of that makes its figures wrong. It means they should be read as a campaigner’s.

Its headline counts are these:

Every one is a count of woods, not hectares, none is England-only, and they mix threat, damage and loss. No page we read publishes the method. The 1,064 and the “more than 1,200” are two readings of an unpublished database, not a trend.

Two of its figures travel badly. The Trust’s habitat page says “Just 2.5% of the UK land is covered in ancient woodland. That’s 609,990 hectares.” That is the UK. England’s inventory was 364,970.81 hectares when we queried it on 26 September 2026, and setting the UK figure beside England is a scope error. The same page says “Up to 70% of ancient woods have been lost or damaged”, with no geography, no period and no denominator, and it counts conifer planting as damage although the inventory still counts those sites as ancient woodland.

The Trust’s August 2026 release on Oaken Wood in Kent is headed “Largest loss of English ancient woodland this century”. The body describes something else: “100 acres (40 hectares) of Oaken Wood in Kent … under threat, after Kent County Council voted to support a quarry expansion”, with a consultation deadline of 10 September. It is a proposal, not a loss, and we have not established what has happened since. “This century” cannot be checked, because no dataset covers it, and we have read only the Trust’s side, not the council’s. If the 40 hectares were lost, it would be more than twice HS2’s 17.66.

The case that this does not matter

The strongest case against this article goes like this. HS2’s 17.66 hectares is 0.0048% of the 364,970.81 hectares in the inventory as queried on 26 September 2026, and still 0.0048% of the total republished three days later. The minister’s figure for 2006 to 2015 was 57 hectares, or 0.02%. Over 27,000 hectares of replanted ancient sites have been brought into restoration since 2010. The planning test was tightened in 2018, and a referral to the Secretary of State was added in 2024. Losses that need an Environmental Statement are, as government says, a matter of public record. And the mapped total is going up, not down. On this view, a national loss series would cost money to confirm that the loss is small.

Each part is sourced, and some of it may be right. But it rests on a numerator that no source we read publishes. The 0.0048% of the September inventory is HS2 alone, because HS2 is the only scheme in our sources with a duty to count. The 0.02% is a 2016 survey estimate for a period that ends in 2015, and only 48 of its 57 hectares are counted in it as woodland loss. The restoration figure is work on sites already in the inventory, not new ancient woodland. And the planning test for an irreplaceable habitat is applied one application at a time: Broadwells Wood has a recorded loss of 1.4 of its 15.6 mapped hectares, which is not a rounding error to the wood.

The national ratio and the per-wood ratio are both true. Neither alone tells you how much England has lost.

What this does not show

It does not show that England is losing large amounts of ancient woodland. It does not show that it is losing very little. It does not show that HS2 is the only loss since 2010: it is the only one that is measured, dated and public in the sources we read. It does not show that the Woodland Trust’s counts are wrong; they are unmethodised and UK-wide, which is different.

What it shows is the shape of the gap: a national map with no dates, a minister declining to collect the data, a policy committed to maintaining an area whose losses it does not track, and a question about loss since 2010 answered with a figure for 2006 to 2015.

Three things would start to close it: an inventory that records when and why a polygon changes, a total of the losses already recorded in Environmental Statements, and a published count of applications referred under the 2024 Direction. None exists in any source we read.

Sources

About This Analysis

This article is part of hostile.eco’s evidence-based environmental advocacy. All claims are sourced and all data is cited. When we get something wrong we publish the correction rather than quietly editing it. See Corrections. If you find an error, please let us know.

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