Representation by FORESTRY COMMISSION (FORESTRY COMMISSION)
- Date submitted
- 1 May 2024
- Submitted by
- Members of the public/businesses
Thank you for consulting the Forestry Commission on this project. As a Non-Ministerial Government Department, the Forestry Commission provide no opinion supporting or objecting to an application. Rather we provide advice on the potential impact that the proposed development could have on trees and woodland, including Ancient Woodland. Ancient Woodlands and Ancient and veteran trees are irreplaceable habitats. Paragraph 186 (c) of the National Planning Policy Framework, 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” While Nationally Significant Infrastructure Projects are not subject to the NPPF, it sets out the importance of these habitats. We note there is no Ancient woodland within the proposed site, the nearest being Grove Wood Ancient Semi Natural Woodland, approximately 50m from the boundary of the site. Grove Wood is unlikely to be affected by the proposed development, as it is outside the minimum recommended buffer zone for Ancient Woodlands, recommendations for a fenced construction exclusion zone as mentioned in the plans should be followed. This would avoid any root compaction or storage of materials within the buffer zone, under the woodland canopy or on the ancient woodland soils. Dust prevention measures should also be utilized during construction to avoid any potential contamination of the ancient woodland. There are also several Ancient and veteran trees identified within the site. We note the planned fenced buffer zones and fenced construction exclusion zones for the ancient and veteran trees to avoid any potential loss or deterioration. Without a detailed tree removal plan it is very difficult to assess the level of woodland and tree removal that the project will require despite estimations used in the Arboricultural report, BNG calculations and Outline Construction Environmental Management plan. However, we do note that a section of woodland (W9) will have to be removed to enable cabling and an access route. The woodland bordering the former Drakelow Power Station site, listed on the Arboricultural Report as Woodlands 8, 9 & 10 are lowland mixed deciduous woodlands on the Priority Habitat Inventory (England). This recognises that under the UK Biodiversity Action Plan they were recognised as being the most threatened and requiring conservation action. The UK Biodiversity Action Plan has now been superseded by the UK Post-2010 Biodiversity Framework but this priority status remains under the Natural Environment & Rural Communities Act 2006. (NERC) Sect 41 – “List of habitats and species of principle importance in England”. This status is not considered or reflected in the documentation, including the BNG baseline and calculation which may need to be amended to account for the priority habitat woodland being considered of high distinctiveness. A scheme that bisects any woodland will not only result in significant loss of woodland cover but will also reduce ecological value and natural heritage impacts due to habitat fragmentation, and have a huge negative impact on the ability of the biodiversity (flora and fauna) to respond to the impacts of climate change. With the Government aspirations to plant 30,000 ha of woodland per year across the UK by 2025. The Forestry Commission is seeking to ensure that tree planting is a consideration in every development not just as compensation for loss. We note the plans for an increase in woodland and tree cover across the site, however the exact amount is unclear except for the 5.51ha stated in the BNG calculations and the maps in the Outline Landscape and Ecological Management Plan. Considering the potential loss of an area of priority habitat woodland and that the new woodlands currently planned are for small blocks primarily for screening purposes, there may be further opportunities for some larger woodland blocks to increase habitat connectivity and benefit biodiversity across the site. The biosecurity of all planting stock needs to be considered to avoid the introduction of pests and diseases. Woodlands need to be climate and pest and disease resilient. Plans should also be in place for the long term management and maintenance of any new woodland, with access needing to be considered for future management. The proposal site is within the National Forest Area, for recommendations of opportunities to improve the level of tree cover and connectivity across the site, especially taking into consideration any loss of priority habitat woodland, the National Forest should also be consulted. We hope these comments have been useful to you. If you need any further information, please do not hesitate to contact me. Best wishes [Redacted] Local Partnership Advisor East & East Midlands Area