Generally support this policy but suggest strengthening it with explicit reference to trees in d)
d) Has a strong emphasis on natural features, including trees, within the streetscene
This would reflect NPPF para 136 and the aspirations of the National Model Design Code.
We support this policy, particularly
e) Successfully integrate existing and incorporate new, natural features, including street trees, into a multifunctional green network that supports quality of place, biodiversity and water management;
We support this policy, particularly the requirement to respect and enhance:
e) Trees, ancient woodland, hedgerows, water features such as rivers and other landscape features and their function as ecological networks;
This is a wide-ranging policy, covering a number of important topics: the general approach to nature conservation and nature recovery; protection of irreplaceable habitats, specifically ancient woodland; and meeting the requirements for Biodiversity Net Gain. There could be value in having separate policies for nature conservation, for trees & woodland and for BNG: this would allow appropriate levels of detail on each, providing clear guidance for planners and applicants, without becoming unwieldy.
We welcome the inclusion of specific information about buffering ancient woodland in point 1e) but note that a 15m buffer is the minimum not the recommended buffer size. The Woodland Trust recommends that where development sites are adjacent to ancient woodland, as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice. A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance. Further information is available in the Trust’s Planners’ Manual for ancient woodland.
We strongly support the approach to biodiversity improvement set out in point 5, through the creation, restoration, enhancement and management of habitats and ecological features, the use of nature-based solutions and taking account of natural capital and the associated ecosystem services.
However we are disappointed to see that 5a) sets a requirement for biodiversity net gain at the legal minimum of of at least 10%. We support setting a greater than 10% target for biodiversity net gain where appropriate. By setting a more ambitious target, the Local Plan increases the chances that an average net gain of at least 10% will be delivered across the Plan area, given the possibility that some sites may not be able to deliver net gain within the Borough or that initiatives intended to deliver such gain may fall short in practice.
We welcome the explicit reference in 5a) to supporting strategic nature recovery initiatives, such as Local Nature Recovery Strategies, and suggest adding the Hampshire Tree Strategy as another important reference.
We welcome the policy point 6b) that the required green space for new developments could be used to provide natural and wild greenspace. We recommend setting targets for access to woodland as part of the Borough's standards.
This policy brings together two issues: the green & blue infrastructure network; and provision / protection of recreational green space; each of which could benefit from having a standalone policy to provide sufficient detail and clarity for planners and applicants.
We support the general approach of this policy, in particular the wording in a) that development proposals should protect and enhance the integrity, quality, connectivity and multi-functionality of the existing green and blue infrastructure network and individual sites.
Design guidance should incorporate the protection and extension of green infrastructure including support for SuDS in all new developments, and encouragement of green links, such as tree lines and hedgerows, to frame residential areas and connect existing habitats. Further information is available in the Trust’s Residential developments and trees https://www.woodlandtrust.org.uk/publications/2019/01/residential-developments-and-trees/
Green infrastructure should be protected, enhanced and integrated into development plans, including through local tree strategies, landscape management plans or urban development briefs. For new planting and soft landscaping, we recommend specification of native species from UK sourced & grown stock. Native trees support other woodland specialist species, while UK sourcing helps address threats of pests & disease, boosting resilience and biosecurity as well as supporting the domestic "green economy" and reducing the carbon footprint of the supply chain. https://www.woodlandtrust.org.uk/plant-trees/uk-sourced-and-grown/
We recommend setting a target for tree canopy cover as part of GI across local plan areas and for specific development sites, ideally of at least 30%, in response to the climate and nature emergencies. Further information is available in the Trust’s Emergency Tree Plan https://www.woodlandtrust.org.uk/publications/2020/01/emergency-tree-plan/
For areas with lower potential, such as small or urban sites, we recommend setting a minimum provision based on the Urban Greening Factor approach. This will support the requirements for Biodiversity Net Gain and make a contribution to the integration of nature recovery strategies.
To achieve ongoing benefits, green infrastructure needs to be protected and maintained. CIL allocations for green infrastructure should include management plans and funding for maintenance. Natural green infrastructure is cost-effective: for example, trees cost less to maintain than regularly-mown turf and have wider biodiversity benefits.
We support the wording that "All planning applications for major development are required to ensure that Sustainable Drainage Systems (SUDs) are used for the management of surface water unless demonstrated to be inappropriate."
Planting trees as part of sustainable drainage schemes (SuDS) can slow the flow of water and reduce surface water runoff by up to 62% compared to asphalt. Trees intercept water as it falls, which is then directly evaporated back into the atmosphere. Roots help the infiltration of water into the soil, lowering the risk of surface water flooding. Tree roots can increase infiltration rates in compacted soils by 63%, and in severely compacted soils by 153%. The soil volumes provided by tree pits within hard surfaces can retain substantial volumes of water, reducing inundation and providing slow release back into natural or engineered drainage systems.
We recommend adding explicit reference to support for natural flood management to ENV10, in line with draft policies CLC1, ENV6, ENV7 and para 7.76.
This could be in a new point f) eg
f) To produce an integrated flood management plan that maximises the use of natural flood management techniques and enhances the green and blue infrastructure network.
We support this policy, especially
g) Maximising green infrastructure to sequester carbon, provide urban cooling, deliver biodiversity net gains, and provide natural flood management (as detailed in Policies ENV6 and ENV7)
The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both.
A rapid increase in the rate of woodland creation has been proposed by the UK’s Committee on Climate Change (CCC), to provide a key mechanism to lock up carbon in trees and soils, provide an alternative to fossil fuel energy and resource-hungry building material, and to stem the declines in biodiversity. The Woodland Trust supports the CCC’s recommended increase in UK woodland cover from its current 13% of land area to at least 19% by 2050 to tackle the biodiversity and climate crises. More information can be found in the Trust’s 2020 publication The Emergency Tree Plan.
We support this positive guidance on provision for street trees.
Integrating trees and green spaces into developments early on in the design process minimises costs and maximises the environmental, social and economic benefits that they can provide. We recommend the guidance published by the Woodland Trust Residential developments and trees - the importance of trees and green spaces (January 2019).
We welcome the approach set out in 6.23 that "every opportunity should be sought to increase natural features in the centre, through new and enhanced green spaces, green links, street trees and other forms of greenery such as green walls".
The wording in the policy SPS3
e) Protect existing, and introduce new green and blue spaces, green links, street trees and other forms of greenery throughout the town centre such as green walls;
is less robust than the wording of 6.23 would suggest is needed.
We recommend strengthening this to read
e) Protect existing, and maximise the potential for new green and blue spaces, green links, street trees and other forms of greenery throughout the town centre such as green walls;
We recommend setting a minimum provision based on the Urban Greening Factor approach. This will support the requirements for Biodiversity Net Gain and make a contribution to the integration of nature recovery strategies.
There are significant areas of ancient woodland to the north east of the site (Long Copse ASNW), east (un-named ASNW at Blacklands Farm), south east (Gravelly Bottom Copse PAWS) and west (Great Binsfield PAWS).
We note that the draft policy point e) requires "the protection of adjacent ancient woodland... through the provision of appropriate buffers;"
The Woodland Trust objects to the inclusion of areas of ancient woodland within development sites. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice. A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance.
The preferred approach is to create new habitat, including native woodland, around existing ancient woodland. This will help reverse the historic fragmentation of this important habitat, contribute to biodiversity net gain, and can also provide accessible green space for nearby residents. Further information is available in the Trust’s Planners’ Manual for ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.
We note that point i) requires that "The existing tree belt on the eastern boundary will be retained in full in order to maintain its visual and biodiversity functions and its identified role in local ecological network mapping. Provision will be made for buffers against the surrounding tree and hedge belts and the Spiers Copse and the Kiln Farm Spreads Ancient Woodland SINCs on the north eastern and western boundary of the site...".
The Woodland Trust objects to the inclusion of areas of ancient woodland within development sites. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice. A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance.
The preferred approach is to create new habitat, including native woodland, around existing ancient woodland. This will help reverse the historic fragmentation of this important habitat, contribute to biodiversity net gain, and can also provide accessible green space for nearby residents. Further information is available in the Trust’s Planners’ Manual for ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.
We note the requirement in point f) for tree retention and additional planting. We welcome the recommendation for native species and suggest adding wording on sourcing .
f) Ensure that the existing trees on site are retained where possible and opportunities are taken to provide additional planting to enhance the landscape structure of the site and the outlook of the residents. Replacement planting will be needed in relation to any trees which are removed (utilising appropriate native species from UK-sourced and grown stock) at a level that will replace the canopy cover lost;
Specifying native species from UK sourced & grown tree stock will help address threats of pests & disease and help boost resilience and biosecurity as well as supporting the domestic "green economy" and reducing the carbon footprint of the supply chain.
We recommend that where there is an unavoidable loss of trees on site, that an appropriate number of suitable replacement trees will be required to be planted, based on maintaining the existing tree canopy cover, therefore likely to be on a greater than 1:1 basis where mature trees are lost. Such a requirement will also support the delivery of biodiversity net gain. A proposed ratio of tree replacement can be found in the Woodland Trust guidance on Local Authority Tree Strategies (July 2016).
We recommend that similar wording be applied to all site allocation policies in line with policy DES2 and para 11.19.
We note the requirement in point i) for tree retention and additional planting and suggest adding wording on species selection.
i) Retain existing trees and take opportunities to enhance the structural landscaping of the site. Additional planting must be provided to reinforce existing tree belts along the northern and eastern boundaries of the built-up area, and will be in keeping with the landscape character of the area, with suitable native species, from UK-sourced and grown stock. Additional planting will also help to minimise the visual impact of the development on the National Landscape, including on views from publicly accessible countryside to the north, east and west of the site; and to reinforce existing groups of trees adjacent to the boundary in the southern part of the site;
Specifying native species from UK sourced & grown tree stock will help address threats of pests & disease and help boost resilience and biosecurity as well as supporting the domestic "green economy" and reducing the carbon footprint of the supply chain.
This site is adjacent to, and may include, areas of important ancient woodland at Worting Wood and Wootton Copse. We are concerned that no mention is made of suitable protection, including buffer zones, for this irreplaceable habitat.
The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Areas of natural woodland, in particular ancient woodland, are vulnerable to pollution, encroachment from development, and habitat fragmentation. It is important that any development is located and designed to avoid damaging ancient woodland, providing buffers for designated sites and protecting connectivity between wildlife habitats. Further information is available in the Trust’s Planners’ Manual for ancient woodland.
We ask that either this site is removed from the plan, or that the site boundaries are redrawn to exclude the ancient woodland, in line with NPPF paragraph 186c, which states: c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists. Exceptional reasons refers to nationally-significant infrastructure projects, not housing developments.
Whether the ancient woodland is within or outside the development site, we recommend a precautionary buffer of 50m unless it can be demonstrated that a smaller buffer would suffice: this buffer can be used for natural woodland regeneration, contributing to biodiversity net gain and/or providing accessible natural green space for local residents.
We suggest rewording point I) to make explicit the need to protect ancient woodland and to acknowledge that where irreplaceable habitats are lost, there can be no possibility of biodiversity net gain.
l) Avoid or mitigate the direct and indirect adverse impacts on key species and habitats, including areas of ancient woodland, rare arable flora and Sites of Importance for Nature Conservation within and adjacent to the site. Loss or harm to irreplaceable habitats must be avoided in order to ensure at least a 10% net gain in biodiversity, and mitigation and compensation for other habitat loss will be required. Opportunities will be taken to secure the creation and management of linkages between existing woodlands;
We recognise the intense pressure to identify and bring forward new sites for housing and employment uses. This pressure makes it all the more important that vital protections for ancient woodland and veteran trees are upheld.
There is an important area of ancient woodland, Peak Copse PAWS, adjacent to the southern edge of the golf course.
We note the wording in f) which calls for protection of Peak Copse through adequate buffering. However this does not make explicit that this is ancient woodland, an irreplaceable habitat, in addition to being a SINC. We suggest amended wording
f) Avoid or mitigate direct and indirect adverse impacts on key species and habitats, including the adjacent Peak Copse ancient woodland Site of Importance for Nature Conservation through adequate buffering, ensuring the retention of irreplaceable habitats and key woodland areas and less managed grasslands and by mitigating and/or compensating any adverse impacts to ensure a net gain in biodiversity. Opportunities will be taken to create and enhance habitat connectivity between existing key habitats;
This site is adjacent to several areas of important ancient woodland including Misholt Copse, Brockhurst Copse, and Cobley Wood, and contains ancient semi-natural woodland at Oaken Copse.
We are concerned that no mention is made in this policy of the ancient woodland nor of any suitable protection, including buffer zones, for this irreplaceable habitat.
The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Areas of natural woodland, in particular ancient woodland, are vulnerable to pollution, encroachment from development, and habitat fragmentation. It is important that any development is located and designed to avoid damaging ancient woodland, providing buffers for designated sites and protecting connectivity between wildlife habitats. Further information is available in the Trust’s Planners’ Manual for ancient woodland.
We ask that either this site is removed from the plan, or that the site boundaries are redrawn to exclude the ancient woodland, in line with NPPF paragraph 186c, which states: c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists. Exceptional reasons refers to nationally-significant infrastructure projects, not housing developments.
Whether the ancient woodland is within or outside the development site, we recommend a precautionary buffer of 50m unless it can be demonstrated that a smaller buffer would suffice: this buffer can be used for natural woodland regeneration, contributing to biodiversity net gain and/or providing accessible natural green space for local residents.
We suggest rewording point e) to make explicit the need to protect ancient woodland. Where irreplaceable habitats are lost, there can be no possibility of biodiversity net gain.
e) Protect and enhance key species and habitats, prevent loss or harm to ancient woodland and other irreplaceable habitats, and, where unavoidable, mitigate the impact on other protected species and habitats; provide appropriate buffers for ancient woodland, and secure the creation and management of linkages that provide high levels of habitat connectivity within the site and to the wider green infrastructure network. Achieve a minimum 10% biodiversity net gain secured by a site management plan;
We recognise the intense pressure to identify and bring forward new sites for housing and employment uses. This pressure makes it all the more important that vital protections for ancient woodland and veteran trees are upheld.