Representation by Forestry Commission (Forestry Commission)
- Date submitted
- 27 October 2023
- Submitted by
- Other statutory consultees
As a prescribed statutory consultee, we are registering to ensure we are consulted and have the opportunity to give advice regarding the proposals based on our forestry/woodland expertise to make sure relevant policy, legislation and good practice is followed, and to help the developer to deliver the best possible outcomes for trees and woodland. As part of this, we wish to ensure that our consultation response on 29th November 2021 has been incorporated into the project's design. Given the scale of development and potential for direct and indirect ecological impact (including the development footprint and as a result of increased air and road traffic), we ask that the project exhausts all efforts to avoid impacts and to maximise opportunities for habitat creation or enhancement. We ask that we are given the opportunity to work with the developer to explore how we can maximise the effectiveness of mitigation, compensation and any net gains in biodiversity. As part of this, we would like to see similar measures made for Heathrow mitigation which included installing the woodfuelled CHP system to heat, cool and power T2/T5 and therefore provide a significant local market for timber production, which has various knock on benefits to the local economy and sustainable management of woodland. We also ask that as the proposal represents development adjacent to Ancient Woodland, the project should not only ensure no loss or deterioration but should seek to secure significant gains in the form of woodland condition enhancement, expansion, greater connectivity between habitats, bringing into management and/or enhancing the buffer zone itself. This should help to safeguard the future condition and extent of ancient woodland. Without this, this could be at best a missed opportunity to enhance/bolster these special habitats, and at worst could result in permanent impacts. This principle is supported by the Environment Act 2021 including the requirement for Biodiversity Net Gain and Local Nature Recovery Strategies which should prioritise protecting and enhancing existing habitat value as far as possible as a first priority. It is also worth noting that the 15m buffer referenced in the Standing Advice for Ancient Woodland, Ancient Trees and Veteran Trees, is a minimum and may need to be larger to account for any direct or indirect impacts associated with the proposed developments. Summary of our November 2021 response is copied below for reference: We are pleased to note that the plans have taken into account the value of ancient woodland, and are respecting the minimum 15 metre buffer zone advised in our joint Standing Advice with Natural England on development affecting ancient woodland. We take note of the commitment to use dust suppression techniques to avoid impact on the woodlands. We ask that any further comments Natural England make on the effects of dust, noise and air pollution effects on ancient woodland are considered, and consider a larger buffer zone around ancient woodland which is likely to be most impacted by these effects,. We also note the recognition that replacement of the loss of broadleaved woodland with replanting is a long-term plan, and that in the interim there will be a loss of habitat. In addition to the on-site replacement planting, we would suggest compensatory (off-site if needs be) woodland to be created in advance of works starting to help reduce the long-term impact of woodland loss. All tree stock should be UK-grown where possible to reduce the carbon footprint of supply, and also to prevent importation of pests and diseases via imported stock. Vigorous biosecurity should be enforced throughout, from the robust use and checking of plant passports, to on-site biosecurity methods. Where possible, we would strongly recommend a commitment to the use of timber in the construction of appropriate buildings, such as hotels. Timber used in buildings locks away carbon, and is a sustainable, renewable construction material. We would expect to see a further commitment to all timber used to be certified under the Forest Stewardship Council (FSC), Programme for the Endorsement of Forest Certification (PEFC), or similar recognised scheme. Page 2 Timber certified by Grown in Britain would also demonstrate a commitment to both sustainability and UK employment, through the reduced production and transport footprints which arise from using UK-grown timber, as opposed to that imported from elsewhere, and supporting the UK forestry industry.