Representation by The Woodland Trust (The Woodland Trust)
- Date submitted
- 3 May 2024
- Submitted by
- Members of the public/businesses
The Woodland Trust is the UK's largest woodland conservation charity and a leading voice in bringing to the attention of government, landowners and the general public the state of the UK’s woods and trees. We own over 1,000 sites across the UK, covering over 30,000 hectares and we have over 500,000 members and supporters. The Trust also campaigns with the support of local communities, to prevent any further destruction of ancient woods and veteran trees. We are an evidence-led organisation, using existing policy and our conservation and planning expertise to assess the impacts of development on ancient woodland and veteran trees. Planning responses submitted by the Trust are based on a review of information provided as part of a planning application. We welcome the opportunity to register as an Interested Party and provide a representation on this scheme. We are concerned about the potential impacts of the development on ancient and veteran trees. The applicant has provided an Arboricultural Survey Report (APP-133), which includes a tree survey detailing trees within proximity to the proposed works. The following trees have been identified as ancient or veteran - T56 (Ancient Oak), T57 (Ancient Oak), T59 (Ancient Willow), T30 (Veteran Lime), T32 (Veteran Oak) and T86 (Veteran Oak). We note that veteran tree buffers have been provided for these trees in line with Natural England and Forestry Commission’s standing advice. However, it is not clear from the plans whether new infrastructure, including widened access tracks, and construction activity will be excluded from these buffer zones. Furthermore, the Tree Survey Methodology within the Arboricultural Survey Report does not specify the approach taken by the consultant to identify ancient and veteran status. In particular, trees T93, T97, T98 and T100 are described as having “Veteran characteristics but not yet of true veteran form”. It is unclear what this assessment means and how it has been reached. Additionally, there are a number of trees in the Arboricultural Survey Report which are not specifically described as having ‘veteran characteristics’, but which we consider may be veteran based on the features and observations detailed. These are T14, T16, T22, T36, T110, T111, T127, T139 and T157. We would expect any methodology used to assess the status of trees as ancient or veteran to be in line with Government guidance, including Planning Practice Guidance (PPG) for Natural Environment, which states: “Ancient trees are trees in the ancient stage of their life. Veteran trees may not be very old but exhibit decay features such as branch death or hollowing. Trees become ancient or veteran because of their age, size or condition. Not all of these three characteristics are needed to make a tree ancient or veteran as the characteristics will vary from species to species.” In summary we are concerned that trees within the development area have not been afforded the appropriate ancient and veteran status, and that the relevant protections for veteran trees have not been fully secured. On the basis of the information provided it appears that the proposals are likely to result in adverse impacts on ancient and veteran trees. We would appreciate the opportunity to address these concerns with the Examining Authority and the Applicant.