Representation by Forestry Commission (Forestry Commission)
- Date submitted
- 26 February 2024
- Submitted by
- Other statutory consultees
Thank you for engaging with the Forestry Commission on this proposal. As the Governments forestry experts, we endeavour to provide as much relevant information to enable the project to reduce any impact on irreplaceable habitat such as Ancient\semi natural Woodland as well as other woodland. Comments below are in line with NPS for Energy (EN1) 5.11.27. There is no ancient woodland within the site boundary. However, there are numerous small woodlands, including lowland mixed deciduous woodlands. Lowland mixed deciduous woodland is on the Priority Habitat Inventory (England). Some of the woodlands within the proposal footprint remain under Obligation of Farm Woodland Premium Scheme grant support, other woodlands have woodland management plans with approved Felling Licences, (Felling Licences may be conditional on restocking and maintaining replanted trees for 10 years). Measures should be taken to ensure project design and management should not prevent the future access to and management of woodlands. Woodlands habitat value generally increases as a result of sustainable woodland management. Farm woodland management can be reliant on (seasonal) access from adjacent farm land, proposals should ensure woodland management access is maintained or enhanced to allow delivery of management objectives, which may include biodiversity value and ecosystem services. It's good to see proposals seek to retain existing woodland, noting the exception of an area of short rotation energy crop plantation. Opportunities should be taken where possible to link and buffer existing woodlands, trees and hedges, which normally increases their ecological value. While not specific to this proposal, the cumulative impact of multiple extensive developments on availability of land for other uses, including woodland creation or farming should be considered. Proposals include creation of 8.1ha native new woodland these should be designed and managed in order to mitigate potential negative impacts of development, and designed to facilitate future sustainable management. When proposing significant planting schemes, there are a number of issues that need to be considered: • Consideration of ecological and cultural (historic environment) features that may be affected by woodland creation • Biosecurity of all planting stock needs to be considered to avoid the introduction of pests and diseases • Woodlands should be designed to be climate and pest and disease resilient.? • Maximise the ecosystem services benefits of all new woodland wherever possible e.g. for flood reduction and also to ensure the planting contributes to a resilient treescape by maximising connectivity across the landscape. • Plans are in place to ensure long term management and maintenance of woodland. The inclusion of the minimum buffer distance of 15m from existing woodland is welcomed as a minimum, however it should be noted that while a 15m buffer limits the impact of the development proposals on existing woodland, once implemented this buffer distance may not adequately mitigate the ongoing shading impact of woodland / trees on solar panels, thereby creating potential conflict between the interests of solar farm management and the retained woodland and trees. A 15m buffer from the stems of adjacent woodland is effectively reduced by the overhang of branches (which can often be 5-10m overhang). Increasing buffer width particularly on north, east and west side of woodlands would reduce shading on the development and help mitigate potential future management conflict, and maintain or enhances ecological value of trees and woodlands. For the purposes of a 50 year project I would encourage decisions to reflect the maximum tree size within the project lifespan. The proposals indicate the proposed (15m) buffer from woodlands does not inhibit placement of cables within this woodland buffer zone. Inclusion of cables within this zone has potential to undermine the purpose and integrity of such buffers. This is particularly important if cabling is to be installed below ground, or is on the ground and allowed to become incorporated in vegetation over time. The woodland/ tree buffer should seek to secure protection of the adjacent habitat, through exclusion of development activity including within the critical root protection zone of woodlands and trees. I would therefore encourage further consideration of the activity undertaken within tree and woodland protection buffers. The Forestry Commission would be able to provide further advice in respect of the above comments.