Chichester Local Plan 2021 - 2039: Proposed Submission

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Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy A15 Loxwood

Representation ID: 4548

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

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.

Change suggested by respondent:

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.

Full text:

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 response:

Comment noted. Criteria 5 of Policy A15 requires that development avoids harm to protected species and important habitat features as well as facilitating biodiversity net gain and habitat connectivity. The Plan also includes specific policies to protect wildlife and require delivery of BNG which will all need to be considered as part of the Neighbourhood Plan site selection process.
Policy A15 does not allocate specific sites, as this will be done through the Neighbourhood Plan process which will need to consider the impact on ancient woodland and veteran trees as part of any site assessment and selection process.

Support

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE8 Trees, Hedgerows and Woodlands

Representation ID: 4549

Received: 16/03/2023

Respondent: The Woodland Trust

Representation Summary:

The Woodland Trust supports this policy.

We welcome the requirement to plant 2 trees for each 1 lost (point 4) and the preference for native species (point 10). In addition, we encourage support for UK & Ireland sourced & grown tree stock.

Full text:

The Woodland Trust supports this policy.

We welcome the requirement in point 4 to plant two trees for each one lost through development, as an effective mechanism to deliver Biodiversity Net Gain and to secure multiple benefits for climate resilience, human well-being and visual amenity.

We note the requirement in point 5 for a minimum buffer zone of 15 metres for ancient woodland. We suggest amending this wording to better deliver the protection for this vital irreplaceable habitat required in the NPPF.

5. Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid root damage (known as the root protection area). For larger developments, a precautionary buffer of up to 50m may be required, unless the applicant can demonstrate that a smaller buffer would be sufficient.

We strongly support the policy in point 10 to encourage planting of a diverse range and variety of native tree species, as this is the best option for biodiversity and resilience. In addition, we recommend a policy preference for UK & Ireland sourced and grown (UKISG) tree stock to support tree health and biosecurity.


Our response:

Support and comment noted

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE5 Biodiversity and Biodiversity Net Gain

Representation ID: 6066

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

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.

Change suggested by respondent:

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

Full text:

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.


Our response:

Proposed change noted. Whilst we would encourage biodiversity net gains above the mandatory requirement, we anticipate that viability constraints may hinder increasing of the minimum percentage above 10% due to the cumulative impact of other developer contributions within the district. These contributions are inclusive of measures which offer biodiversity benefits and mitigations to impacts of development within the Local Plan Area. We therefore consider our position reasonable in that the legislated minimum BNG requirements would be imposed in conjunction with other biodiversity measures.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P5 Spaces and Landscaping

Representation ID: 6067

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

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.

Change suggested by respondent:

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.

Full text:

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.


Our response:

Objection and proposed change noted. Policy P5 expects development to exploit opportunities for appropriate new trees planting, and Policy NE8 requires proposals to maximise opportunities for tree planting, as well as all major development to provide street tree planting.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P14 Green Infrastructure

Representation ID: 6068

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We recommend strengthening this policy with reference to the emerging statutory requirements for Local Nature Recovery Strategies.

Change suggested by respondent:

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;

Full text:

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;


Our response:

Recommend strengthening policy with reference to the emerging statutory requirements for Local Nature Recovery Strategies

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy P15 Open Space, Sport and Recreation

Representation ID: 6069

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

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.

Change suggested by respondent:

We request that the policy is applied as a minimum, and that higher provision is made where feasible

Full text:

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.



Our response:

Objection noted.

It should be noted that the standards set out in Table 6.3 are minimum standards. However, following a review of the open space standards (in the Open Space, Sport Facilities, Recreation Study and Playing Pitch Strategy Update 2024) a separate standard for accessible natural green space of 1.2ha per 1000 population is proposed to be include in Table 6.3. In addition it is proposed to add reference to the Woodland Trust’s Woodland Access Standards under the accessibility standard for natural green space.

Object

Chichester Local Plan 2021 - 2039: Proposed Submission

Policy NE8 Trees, Hedgerows and Woodlands

Representation ID: 6070

Received: 16/03/2023

Respondent: The Woodland Trust

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

We note the requirement in point 5 for a minimum buffer zone of 15 metres for ancient woodland. We suggest amending this wording to better deliver the protection for this vital irreplaceable habitat required in the NPPF.

We strongly support the policy in point 10 to encourage planting of a diverse range and variety of native tree species, as this is the best option for biodiversity and resilience. In addition, we recommend a policy preference for UK & Ireland sourced and grown (UKISG) tree stock to support tree health and biosecurity.

Change suggested by respondent:

Suggested amendment:

5. Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid root damage (known as the root protection area). For larger developments, a precautionary buffer of up to 50m may be required, unless the applicant can demonstrate that a smaller buffer would be sufficient

Full text:

The Woodland Trust supports this policy.

We welcome the requirement in point 4 to plant two trees for each one lost through development, as an effective mechanism to deliver Biodiversity Net Gain and to secure multiple benefits for climate resilience, human well-being and visual amenity.

We note the requirement in point 5 for a minimum buffer zone of 15 metres for ancient woodland. We suggest amending this wording to better deliver the protection for this vital irreplaceable habitat required in the NPPF.

5. Proposals should have a minimum buffer zone of 15 metres from the boundary of ancient woodland or veteran trees to avoid root damage (known as the root protection area). For larger developments, a precautionary buffer of up to 50m may be required, unless the applicant can demonstrate that a smaller buffer would be sufficient.

We strongly support the policy in point 10 to encourage planting of a diverse range and variety of native tree species, as this is the best option for biodiversity and resilience. In addition, we recommend a policy preference for UK & Ireland sourced and grown (UKISG) tree stock to support tree health and biosecurity.


Our response:

Paragraph 035 of the PPG Natural Environment Guidance refers to the Forestry Commission and Natural England advice which is a material consideration in appropriate circumstances. The buffer zone recommendation is as set out at criterion 5, however, the wording “Where assessment shows other impacts are likely to extend beyond this distance, the proposal is likely to need a larger buffer zone” in the Guidance recommendation will also be added to the policy.

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