Draft Local Plan Review

Policy P10 Natural Environment
Whilst we are pleased to see the references to ancient woodland in the 'Biodiversity and Geodiversity' paragraph of Policy P10, it still does not reflect national planning policy as we highlighted in our earlier Issues & Options consultation response in November 2015. We therefore raise two objections to this Local Plan Review document -
1. The reference to ancient woodland in the 'Biodiversity and Geodiversity' paragraph of Policy P10 should also include a reference to ancient and veteran trees.

It is crucially important that there is no further avoidable loss of ancient and veteran trees through development pressure, mismanagement or poor practice. The Ancient Tree Forum (ATF) and the Woodland Trust would like to see all such trees recognised as historical, cultural and wildlife monuments scheduled under TPOs and highlighted in plans so they are properly valued in planning decision-making. There is also a need for policies ensuring good management of ancient trees, the development of a succession of future ancient trees through new street tree planting and new wood pasture creation, and to raise awareness and understanding of the value and importance of ancient trees. The Ancient Tree Hunt (http://www.ancient-tree-hunt.org.uk/) is designed specifically for this purpose and has identified ancient trees like the ancient Sweet Chesnut (grid ref: SP153 803) at the Lode Lane intersection with the Solihull Bypass.

'Keepers of Time' (Defra, 2005) - now re-affirmed in the Government's Forestry Policy Statement - requires that: 'Ancient and native woodland and trees should make an increasing contribution to our quality of life....Take steps to avoid losses of ancient woodland and of ancient and veteran trees' (P.10/11).
Other local authorities are already including support for protection of ancient trees in their planning documents -

Torbay Local Plan (adopted December 2015) Policy C4 - Trees, hedgerows and natural landscape features
"Development will not be permitted when it would seriously harm, either directly or indirectly, protected or veteran trees, hedgerows, ancient woodlands or other natural features of significant landscape, historic or nature conservation value".
Deane Site Allocations and Development Management Plan (adopted Dec 2016) Policy ENV1: Protection of trees, woodland, orchards and hedgerows
"Development should seek to minimise impact on trees, woodlands, orchards, historic parklands and hedgerows of value to the areas landscape, character or wildlife and seek to provide net gain where possible. Where the loss is unavoidable, the works (or development) should be timed to avoid disturbance to species that are protected by law. Adequate provision must be made to compensate for this loss. Development which would result in the loss of Ancient Woodland, Aged or Veteran Trees will not be permitted. The proper management of this resource for nature conservation purposes will be sought".
2. The wording of the ancient woodland protection in the 'Biodiversity and Geodiversity' paragraph of Policy P10 does not provide the absolute protection, other than in wholly exceptional circumstances, that ancient woodland requires. We would also like to see mention of Natural England and the Forestry Commission's standing advice for Ancient woodland and veteran trees: protecting them from development - https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences.

Emerging national policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The Communities and Local Government (CLG) Select Committee published its report following its June 2014 inquiry into the 'Operation of the National Planning Policy Framework (NPPF)', in which it has specifically recognised the need for better protection for ancient woodland (Tues 16th Dec 2014). The CLG Select Committee report states: 'We agree that ancient woodland should be protected by the planning system. Woodland that is over 400 years old cannot be replaced and should be awarded the same level of protection as our built heritage. We recommend that the Government amend paragraph 118 of the NPPF to state that any loss of ancient woodland should be "wholly exceptional". We further recommend that the Government initiate work with Natural England and the Woodland Trust to establish whether more ancient woodland could be designated as sites of special scientific interest and to consider what the barriers to designation might be.' http://www.publications.parliament.uk/pa/cm201415/cmselect/cmcomloc/190/190.pdf.
This shows a clear direction of travel, recognising that the NPPF does not currently provide sufficient protection for ancient woodland. Until the NPPF is amended there is a clear role for Local Plans and associated documents to provide this improved level of protection and to ensure that irreplaceable habitats get the same level of protection as heritage assets enjoy under the NPPF.

This is already being reflected in local planning policy -

The Bristol City Council - Site Allocations and Development Management Policies (Adopted July 2014) [part of Local Plan) Policy DM17: Development Involving Existing Green Infrastructure
"Trees
All new development should integrate important existing trees. Development which would result in the loss of Ancient

Torbay Local Plan (adopted December 2015) Policy C4 - Trees, hedgerows and natural landscape features
"Development will not be permitted when it would seriously harm, either directly or indirectly, protected or veteran trees, hedgerows, ancient woodlands or other natural features of significant landscape, historic or nature conservation value".
Deane Site Allocations and Development Management Plan (adopted Dec 2016) Policy ENV1: Protection of trees, woodland, orchards and hedgerows
"Development should seek to minimise impact on trees, woodlands, orchards, historic parklands and hedgerows of value to the areas landscape, character or wildlife and seek to provide net gain where possible. Where the loss is unavoidable, the works (or development) should be timed to avoid disturbance to species that are protected by law. Adequate provision must be made to compensate for this loss. Development which would result in the loss of Ancient Woodland, Aged or Veteran Trees will not be permitted. The proper management of this resource for nature conservation purposes will be sought".
We propose amended wording to the ancient woodland protection in the 'Biodiversity and Geodiversity' paragraph of Policy P10 to read (upper case amendments) - Designated sites, ancient woodland, ANCIENT AND VETERAN TREES and priority habitats SHALL BE PROTECTED OTHER THAN IN WHOLLY EXCEPTIONAL CIRCUMSTANCES AND shall include the establishment of buffers to any new development so that they connect with existing and created green infrastructure assets.

We would also like to see protection for ancient woodland and ancient trees, as well as support for new woodland creation, set out in a separate dedicated Trees & Woodland Policy, backed up by a Trees & Woodland SPD.

Policy P14 Amenity
We are pleased to see the support for protecting existing trees, hedgerows and woodlands, as well as the support for new woodland creation. We note that the listed abbreviations include a reference to the WAST (Woodland Access Standard) but there is no reference to this anywhere in the Local Plan Review text.
We assume that this is derived from research by the Woodland Trust set out in our Space for People publication - https://www.woodlandtrust.org.uk/publications/2015/02/space-for-people/. We believe that the WASt can be an important policy tool complimenting other access standards used in delivering green infrastructure for health benefits.

The WASt is complimentary to Natural England's ANGST+ and is endorsed by Natural England (further details on Space for People can be provided on request). The Woodland Trust Woodland Access Standard recommends:
- that no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size
- that there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round-trip) of people's homes.

We would therefore like to see the WASt referenced in the supporting text for Policy P14 Amenity.