Representation by Forestry Commission (Forestry Commission)
- Date submitted
- 12 July 2024
- Submitted by
- Members of the public/businesses
Thank you for consulting the Forestry Commission on this project. 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. We have assessed the route map of the proposed order limits and can confirm there is no ancient woodland within the order limit. However we do note the presence of a number of veteran trees located within the order limits, as highlighted in the Environmental Statement. Ancient and veteran trees are irreplaceable habitats. As stated in the National Networks National Policy Statement (March 2024): Para 5.62: “Ancient woodland and ancient and veteran trees are irreplaceable habitats. England’s ancient woodlands and ancient and veteran trees support high levels of biodiversity. They are home to a quarter of England’s priority species for conservation and once lost they cannot be recreated. They also deliver many ecosystem services including clean water and healthy soils, carbon storage, support for people’s wellbeing and their long-standing cultural values. The Keepers of Time published in 2022 updates the government's policy to recognise the value of England’s ancient and native woodlands and ancient and veteran trees. It restates the government's commitment to evaluate the threats facing these habitats and sets out updated principles and objectives to protect and improve these habitats for future generations.” Para 5.63: “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 ancient and veteran trees unless there are wholly exceptional reasons (for example, where the public benefit would clearly outweigh the loss or deterioration of habitat) and a suitable compensation strategy exists.” We do note the relatively small incursion areas into the Root Protection Zones of veteran trees T038, T136 & T139, together with the planned Construction Exclusion Zone fencing and ground protection. However, given the small level of incursion, together with the potential to cause loss or deterioration to the veteran trees, is it not possible to avoid the root protection areas completely? There are several areas of Lowland Mixed Deciduous woodland within the site area. Lowland Mixed Deciduous woodlands are on the National Forest Inventory and the Priority Habitat Inventory (England). They were recognized under the UK Biodiversity Action Plan as being the most threatened, requiring conservation action. The UK Biodiversity Action Plan has now been superseded but this priority status remains under the Natural Environment & Rural Communities Act 2006. (NERC) Sect 40 “Duty to conserve and enhance biodiversity” and Sect 41 – “List of habitats and species of principle importance in England”. Lowland Mixed Deciduous Woodland Identified within the Order limits: 1.86ha – Approximate location SK 8218 5664 0.35ha - Approximate location SK 8147 5601 0.28ha - Approximate location SK 8140 5593 0.62ha - Approximate location SK 8127 5582 0.63ha - Approximate location SK 8103 5589 1.14ha - Approximate location SK 8048 5592 0.73ha - Approximate location SK 8030 5576 0.65ha – Approximate location SK 8022 5558 2.07ha - Approximate location SK 7998 5498 1.75ha - Approximate location SK 7998 5498 1.57ha - Approximate location SK 7814 5319 0.62ha - Approximate location SK 7699 5521 Fragmentation is one of the greatest threats to lowland mixed deciduous woodland. Even if parts of the woodlands were to be retained, woodlands can suffer loss or deterioration from nearby development through damage to soils, roots and vegetation and changes to drainage and air pollution from an increase in traffic, particularly during the construction phase of a development. A scheme that bisects any woodland will not only result in significant loss of woodland cover but will also reduce the ecological value and natural heritage impacts due to habitat fragmentation, and have a huge negative impact on the ability of the biodiversity (flora and fauna) to respond to the impacts of climate change. For any woodland within the development boundary, land required for temporary use or land where rights are required for the diversion of utilities you must take into consideration the Root Protection Zone. The Root Protection Zone (as specified in British Standard 5837) is there to protect the roots of trees, which often spread out further than the tree canopy. Protection measures include taking care not to cut tree roots (e.g., by trenching) or causing soil compaction around trees (e.g., through vehicle movements or stacking heavy equipment) or contamination from poisons (e.g., site stored fuel or chemicals). We note the plans for the planting of native woodland belts together with the enhancement of the offsite plantation woodland. With the Government aspiration to increase tree and canopy cover to 16.5% of land area in England by 2050. The Forestry Commission is seeking to ensure that tree planting is a consideration in every development not just as compensation for loss. There may be the opportunity to create some larger woodland blocks to increase connectivity and biodiversity across the wider site area, especially in the areas adjacent to the retained lowland mixed deciduous woodland blocks. The biosecurity of all planting stock needs to be considered to avoid the introduction of pests and diseases. Woodlands need to be climate, pest and disease resilient. Plans should also be in place for the long term management and maintenance of any new woodland, with access needing to be considered for future management. We hope these comments have been useful to you. If you require any further information, please do not hesitate to contact me. Yours sincerely Sandra Squire Local Partnership Advisor