Representation by Woodland Trust (Woodland Trust)
- Date submitted
- 25 February 2020
- Submitted by
- Non-statutory organisations
The Trust holds significant concerns with regards to the impact that this scheme is proposing to have on areas of ancient woodland that are part of the Avon Gorge SAC/SSSI. The ancient woods within the Avon Gorge are a key element of the site’s Site of Special Scientific Interest (SSSI) designation, with the woods containing many nationally rare and scarce plant species, including a number of whitebeam species unique to Avon Gorge. Furthermore, the ancient woodlands of the Avon Gorge are recognised as an intrinsic part of the reason that this site is designated as a Special Area of Conservation (SAC). The priority qualifying features of the SAC designation given to Avon Gorge relate to the species composition within the woodland (H9180) due to its populations of nationally rare whitebeam species and small-leaved limes. It is recognised that there will be direct losses of ancient woodland from this scheme, however it is also vitally important that indirect impacts are fully considered during the assessment of the scheme’s impact on ancient woodland. Construction impacts such as noise, light, vibration and dust pollution will all impact on the ancient woodland and its wildlife, with similar indirect impacts also likely to occur during the operational phase of the project. The combination of direct and indirect impacts will likely be highly detrimental to the SAC/SSSI designated ancient woodland, leading to losses in local biodiversity. In summary, the Woodland Trust objects to the proposed development on the grounds of impact to irreplaceable ancient woodland that holds a number of nationally and internationally significant designations. We consider it critical that this development does not result in the direct loss of the ancient woodland, as this will affect the overall integrity of the site and is contrary to the conservation objectives of the Avon Gorge site. We therefore request that a Habitat Regulations Assessment is undertaken to its full extent to determine if the proposed development will have a Likely Significant Effect on this internationally designated site. The Trust intends to provide fuller comments as part of a written representation later in the process and hope that these comments are sufficient at present.