Revised Development Strategy

Whilst we are pleased to see the reference under the 'Environment' heading of the Strategic Vision (section 3) to the general principle of 'Protecting biodiversity, high quality landscapes, heritage assets and other areas of significance', we would like to see this aim specified in more detail in this Strategy. We appreciate that it may be intended to cover this elsewhere in the Local Plan process, but we contend that it is important to set this out in the actual development strategy itself.

Specifically, we would like to see -


1. Absolute protection for ancient woodland and ancient trees in accordance with national policy. Every ancient wood is a unique habitat that has evolved over centuries, with a complex interdependency of geology, soils, hydrology, flora and fauna. This requires absolute protection in accordance with national policy as set out below.

Ancient woodland, together with ancient/veteran trees, represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 84% of ancient woodland in the West Midlands has no statutory protection.

With Warwick DC showing a slightly above average ancient woodland resource at 2.64% of land area compared to a Great Britain average of 2.40%, it is vital that this valuable natural resource is absolutely protected.

It is also important that there is no further avoidable loss of ancient 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 already identified ancient trees across the District, such as the ancient oak beside the railway line at Old Milverton (grid ref: SP 302 674).

Government policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The new National Policy Planning Framework clearly states: "...planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland..." (DCLG, March 2012, para 118).

However this NPPF wording should be considered in conjunction with other stronger national policies on ancient woodland -
- The Government's policy document 'Keepers of Time - A statement of Policy for England's Ancient & Native Woodland' (Defra/Forestry Commission, 2005, p.10) states: 'The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland'.

- The Government's Independent Panel on Forestry states: 'Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time - A statement of policy for England's ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.' (Defra, Final Report, July 2012). This has been endorsed by the response in the recent Government Forestry Policy Statement (Defra Jan 2013): 'We recognise the value of our native and ancient woodland and the importance of restoring open habitats as well as the need to restore plantations on ancient woodland sites. We, therefore, confirm our commitment to the policies set out in both the Open Habitats Policy and Keepers of Time, our statement of policy for England's ancient and native woodland'.

- The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: 'The Government is committed to providing appropriate protection to ancient woodlands....'.

- The new Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England's Wildlife & Ecosystem Services, Defra 2011, see 'Forestry' para 2.16) states that - 'We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site'.

- The West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) Objective EB2 seeks: 'To prevent any further loss of ancient woodland and to enhance ancient semi-natural woodland and trees with new native woodland planting...'


An example of good Local Authority policy on ancient woodland is provided by North Somerset Council Core Strategy Adopted April 2012 -
'Policy CS4: Nature conservation
North Somerset contains outstanding wildlife habitats and species. These include limestone grasslands, traditional orchards, wetlands, rhynes, commons, hedgerows, ancient woodlands and the Severn Estuary. Key species include rare horseshoe bats, otters, wildfowl and wading birds, slow-worms and water voles.
The biodiversity of North Somerset will be maintained and enhanced by:...
3) seeking to protect, connect and enhance important habitats, particularly designated
sites, ancient woodlands and veteran trees'.

The Plan for Stafford Borough - Pre-submission publication: Jan 2013 states in Policy N5 that: 'New developments will be required to include appropriate tree planting, to retain and integrate healthy, mature trees and hedgerows, and replace any trees that need to be removed. Development will not be permitted that would directly or indirectly damage existing mature or ancient woodland, veteran trees or ancient or species-rich hedgerows'.

We would therefore like to see this Development Strategy contain a policy to read: 'Planning permission will be refused for developments resulting in the loss of or adverse effects upon ancient woodland or ancient trees' in accordance with the latest national policy.



2. As well as 'protecting' biodiversity, it is also critically important to EXPAND priority habitats like native woodland in order to deliver the wider aspirations of the Government's Natural Environment White Paper to achieve the 'landscape scale' habitat outcomes set out in the biodiversity review by Sir John Lawton (Making Space for Nature, DEFRA, September 2010).

The National Planning Policy Framework (NPPF) supports the need for more habitat creation by stating that: 'Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (DCLG, March 2012, para 114). Also para 117 states that: 'To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'.

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim - 'Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England', (Biodiversity 2020: A strategy for England's wildlife and ecosystems services, DEFRA 2011, p.26).

A reading of these new policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that habitat expansion, like native woodland creation, should form a high priority for this Strategic Policies document.

Woodland creation also forms a significant element in the conclusions of the Government's Independent Panel on Forestry, which states: 'Ensure woodland creation, tree planting and maintenance is part of the green space plan for new commercial and housing development' (Defra, Final Report, July 2012). This has now been endorsed by the response in the recent Government Forestry Policy Statement (Defra Jan 2013): 'We believe that there is scope for increasing England's woodland cover significantly to deliver economic, social and environmental benefits. We want to see significantly more woodland in England. We believe that in many, although not all, landscapes more trees will deliver increased environmental, social and economic benefits. We particularly want to see more trees and woodlands in and around our towns and cities and where they can safeguard clean water, help manage flood risk or improve biodiversity'.

The refreshed West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) calls for: '...a significant increase in the West Midlands tree and woodland cover where strategic target areas continue to be identified' (Objective TWC2).

There are already good examples emerging of suitable wording on habitat expansion emerging in other Local Plan documents -

Solihull Draft Local Plan - Pre-Submission draft January 2012
Policy P10 Natural Environment
The Council will seek to protect, enhance and restore the diverse landscape features of the Borough and to create new woodlands and other characteristic habitats, so as to halt and where possible reverse the degrading of the Arden landscape and promote local
distinctiveness.
The Council will seek to conserve, enhance and restore biodiversity and geodiversity, to create new woodlands and other habitats and to protect and enhance semi-natural ancient woodland and green infrastructure assets across the Borough.

Draft Core Strategy for Chesterfield Borough Council - Feb 2012
5.25 Both the Chesterfield and North East Derbyshire Sustainable Community
Strategy and the Chesterfield Greenprint aim to increase the tree cover in the
borough for the benefit of both people and wildlife as well as improve
landscape quality. Tree and woodland planting will help the borough to
respond to climate change and flood alleviation, as well as improve
biodiversity and levels of amenity.


We would therefore like to see this Development Strategy contain a policy to read - 'development proposals should conserve, protect, enhance and expand features of biological or geological interest, including Biodiversity Action Plan habitats and species, and native woodland.