Representation by Woodland Trust (Woodland Trust)
- Date submitted
- 4 September 2019
- Submitted by
- Members of the public/businesses
As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. We own over 1,000 sites across the UK, covering around 24,000 hectares (59,000 acres) and we have 500,000 members and supporters. The Trust is concerned about the direct loss of 0.4ha from two ancient woods and the impacts on 11 veteran trees, two of which are proposed to be removed. Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since 1600AD. Ancient woodland takes centuries to develop and evolve, creating vital links between plants, animals and soils – a habitat for many of the UK's most important and threatened fauna and flora species. Therefore it cannot be re-created and cannot afford to be lost. Natural England’s standing advice on veteran trees states that they “can be individual trees or groups of trees within wood pastures, historic parkland, hedgerows, orchards, parks or other areas. They are often found outside ancient woodlands. They are irreplaceable habitats with some or all of the following characteristics… A veteran tree may not be very old, but it has decay features, such as branch death and hollowing. These features contribute to its biodiversity, cultural and heritage value.” The National Planning Policy Framework, paragraph 175 states: “When determining planning applications, local planning authorities should apply the following principles: c) 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 reasons58 and a suitable compensation strategy exists”. Paragraph 5.32 of the National Policy Statement for National Networks also contains wording related to the protection of ancient woodland and veteran trees, stating: “The Secretary of State should not grant development consent for any development that would result in the loss or deterioration of irreplaceable habitats including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the national need for and benefits of the development, in that location, clearly outweigh the loss.” While the Trust acknowledges that the applicants are proposing measures to compensate for the loss of ancient woodland, including translocation of ancient woodland soil and bringing existing areas of ancient woodland into management, we consider that these measures can only be considered compensation and cannot make up for the loss of irreplaceable ancient woodland. The same applies in the case of veteran trees. In order to avoid impact, veteran trees must be afforded appropriate protection in line with Natural England’s standing advice, with buffer zones of 15 times the diameter of the tree or 5 metres beyond the canopy if that is greater. In summary, the Trust is opposed to the proposed scheme on the basis of impacts to ancient woodland and veteran trees and as such we consider that this scheme in its current form contravenes national planning policies due to the loss of irreplaceable habitats.