Representation by Woodland Trust (Woodland Trust)
- Date submitted
- 30 October 2020
- Submitted by
- Non-statutory organisations
The Woodland Trust is the UK's leading woodland conservation charity and we aim 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. We are concerned about the direct loss of 0.68 hectares of Dukes Bank Wood (grid reference: NZ175998), an area of ancient woodland that falls on both sides of the current A1. Dukes Bank Wood is also a Site of Special Scientific Interest (SSSI) and a Local Wildlife Site (LWS). 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. 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.” The proposed scheme will result in direct loss to SSSI-designated Dukes Bank Wood, with loss of habitat and compaction of the valuable ancient woodland soils. As well as direct impacts, indirect impacts from construction and operation of the scheme can also be expected in the form of habitat fragmentation, noise and light pollution, increased exposure, dust pollution and a potential increase in traffic emissions (leading to increased deposition of nitrates). We acknowledge that the applicant is proposing compensation planting at a ratio of 12:1. We believe that the level of compensation needs to be commensurate with the irreplaceable nature of the habitat lost and therefore ask that the applicant adopts a ratio of 30 hectares of new planting for every one hectare of ancient woodland lost. We are also concerned about the translocation of ancient woodland soils for new areas of planting as we understand that invasive species such as Himalayan Balsam are present in the area and any translocation process could aid the spread of such species. In summary, the Trust is opposed to the proposed scheme on the basis of loss, damage and deterioration to a SSSI-designated ancient woodland. On account of the impact to irreplaceable habitat, we consider that this scheme in its current form contravenes national planning policies.