Chichester Local Plan 2021 - 2039: Proposed Submission

The Woodland Trust strongly supports this policy which is a practical measure to deliver the emerging statutory requirements for Local Nature Recovery Strategies and Biodiversity Net Gain.

To be effective, the Strategic Wildlife Corridors must be protected with buffer zones and their connectivity must be protected in site allocations and individual planning applications. All ancient, veteran and notable trees within the Strategic Wildlife Corridors should have root protection areas defined and protected, in line with the draft Policy NE8 point 5.

The Woodland Trust supports this policy and the protection for ancient woodland as an irreplaceable habitat, and the exclusion of irreplaceable habitats from net gain calculations.

We support setting a greater than 10% target for 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 District or that initiatives intended to deliver such gain may fall short in practice.

Therefore we suggest the following wording change to make the policy more effective:
1. Development proposals adhere to the NPPF mitigation hierarchy, and in addition, demonstrate that proposals provide a minimum of 10% net gain in biodiversity against a pre-development baseline. Where it is achievable, a 20%+ onsite net gain is encouraged.

The Woodland Trust supports this policy. In particular, we welcome policy to prioritise the use of locally native species and the retention of existing trees (point 8), for to connecting existing green infrastructure corridors and seek to create new ones (point 9), supporting appropriate new tree planting (point 10) and wildlife passages (point 11).


We recommend setting a tree canopy cover target to support the Council’s Climate Emergency Action Plan. The Woodland Trust supports the UK Committee on Climate Change’s recommended increase in UK woodland cover from the current 13% of land area to at least 19% by 2050.

The Woodland Trust supports this policy. We recommend strengthening it with reference to the emerging statutory requirements for Local Nature Recovery Strategies.

Amended text proposed:
1. The proposals maintain or, where appropriate, incorporate improvements to the existing network of green infrastructure, or the restoration, enhancement or creation of additional provision areas, and contribute delivery of the Local Nature Recovery Strategy;

The Woodland Trust supports point 3 that there should be no adverse impact on biodiversity from development affecting open space.

We welcome the inclusion of natural greenspace in Table 6.3 – Minimum Open Space Quantity and Access Standards. However we note that the standard set (1ha within 600m) falls short of Natural England’s Accessible Natural Green Space Standard of accessible natural green space of 2ha within 300m, In addition, the Woodland Trust's Woodland Access Standard recommends 2ha of accessible woodland within 500m.
We request that the policy is applied as a minimum, and that higher provision is made where feasible.

We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

The broad site allocation lacks specific detail on its environmental impact, therefore we are unable to either support or object at this stage.

We welcome point 5 requiring habitat protection. We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

Our preference would be for the site boundary to be withdrawn to exclude the area of ancient woodland.

We recommend appending new wording to 6. Deliver a measurable net gain to biodiversity in accordance with Policy NE5 (Biodiversity and Biodiversity Net Gain), and protect and enhance the setting of Brand Hole Copse Local Nature Reserve and areas of ancient woodland and other priority habitats, including chalk streams, including provision of a 50m buffer unless the developer can demonstrate that a smaller buffer would suffice.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development, in line with the protection given to irreplaceable habitats in NPPF paragraph 180c. This site includes 1ha ancient woodland at grid ref SU84450536, and is adjacent to Upper Rouse Copse (SU84320605) 1.99 Ha and East Broyle Copse (SU85180654) 6.22 Ha.

Development which would result in the loss of ancient woodland, aged or veteran trees should not be permitted. Direct impacts that would lead to damage or loss of ancient woodland habitat or veteran trees must either be avoided or compensated for if the need is judged to be truly exceptional; there is no appropriate mitigation for the loss of irreplaceable habitats.

We recommend redrawing the site boundaries to exclude areas of ancient woodland from land allocated for development. As a precautionary principle, a minimum 50m 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.

We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

The broad site allocation lacks specific detail on its environmental impact, therefore we are unable to either support or object at this stage. We welcome point 5 requiring habitat protection. We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

The broad site allocation lacks specific detail on its environmental impact, therefore we are unable to either support or object at this stage. We welcome point 9 requiring habitat protection. We request that any future allocation requires a site survey for ancient woodland and ancient & veteran trees, and that appropriate buffers are applied, before the number and layout of dwellings is agreed.

We recommend adding wording:
"Deliver a measurable net gain to biodiversity in accordance with Policy NE5 (Biodiversity and Biodiversity Net Gain), and protect and enhance the setting of existing important trees and hedgerows in accordance with Policies NE8 and P5."

The Woodland Trust objects to site allocations that include ancient and veteran trees unless adequate protection is specified. Such allocations are inconsistent with the enhanced protection afforded ancient woodland in the NPPF paragraph 180c. This site includes two notable trees, both pedunculate oaks, recorded on the Ancient Tree Inventory, Tree Id: 212591 and Tree Id: 212590. We are concerned that the policy makes no reference to irreplaceable habitats or protected trees.