Representation by Woodland Trust (Woodland Trust)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
Dear Planning Inspector, The Woodland Trust is the UK's leading woodland conservation charity, aiming to protect native woods, trees and their wildlife for the future. We own over 1,000 sites across the UK, covering over 30,000 hectares and we have over 500,000 members and supporters. We are an evidence-led organisation, applying existing policy and using expertise to assess the impacts of development on ancient woodland and ancient and veteran trees. Our representation is based on a review of the information provided as part of this Development Consent Order submission. We welcome the opportunity to register as an Interested Party and provide a representation on this scheme. The Trust has held an objection to the proposed route of the Lower Thames Crossing (LTC) scheme since 2016 on account of its potential for impact on ancient woodland, veteran trees and our own Ashenbank Wood site, as well as the considerable carbon and nitrogen emissions associated with the scheme. While consultations and engagement with the LTC project team over the years appear to have enabled reductions in the loss of irreplaceable habitats, we have been hampered by a lack of transparency in the course of public consultations and the limited information made available to the public. While full details of impacts on the natural environment appear to have now been provided, they confirm significant impact on both nature and climate. The scheme is proposed to result in the loss of 7.62ha of ancient woodland and permanent loss of six ancient and veteran trees. With these losses, the LTC scheme would constitute the greatest single loss of irreplaceable ancient woodland and veteran trees of any proposed road scheme currently under consideration in England. Ancient woodland and veteran trees are nationally important habitats and therefore great weight should be afforded to their protection in line with the National Networks National Policy Statement (NNNPS). Where such protections cannot be delivered, proposals should be refused. Regarding the Trust’s own Ashenbank Wood site, it is proposed to reroute a National Cycle Route (NCR177) through part of the woodland, however, we have significant concerns regarding these proposals. In engaging with the LTC project team regarding the NCR177 diversion through our site, it was apparent that the team had been unaware of some of the constraints within this area, such as archaeological features (remnants of war camps) and veteran trees. It was apparent that the impacts on these features have not been fully considered. Further to the above, once built, the scheme will result in significant nitrogen pollution and carbon emissions during its operation. Carbon emissions contribute greatly to climate change and Government ambitions and policy are clear that such emissions need to be reduced in the coming years. Nitrogen pollution can impact on sensitive natural habitats, such as ancient woods and veteran trees, over a great distance from the source of pollution; operation of the scheme and greater vehicle use is likely to adversely affect dozens of ancient woodland sites and individual veteran trees within the vicinity of the scheme. In conclusion, the Woodland Trust strongly objects to the Lower Thames Crossing scheme on account of severe impacts to ancient woodland and ancient and veteran trees, resulting in significant and irreversible loss and long-term deterioration of these nationally important irreplaceable habitats. We consider that the scheme should not be taken forward unless significant design changes can be made to avoid the hugely damaging and irreversible impacts on the natural environment, to address the impacts on our own Ashenbank Wood site, and to greatly reduce the anticipated carbon and nitrogen emissions associated with the scheme. Our concerns detailed above have been supported by means of our online petition (REDACTED), which has been signed by 11,024 of the Trust’s supporters who agree that the scheme will have an unacceptable impact on biodiversity and climate. Finally, while we have identified the above information during the course of our initial assessment of the documentation made available, we ask that if there are additional issues uncovered during the course of our assessment of the submission’s documentation, that we may raise such issues accordingly. Yours sincerely, Jack Taylor Lead Campaigner - Woods Under Threat Woodland Trust