Chichester Local Plan 2021 - 2039: Proposed Submission

Reword "historic buildings and sites" to "historic buildings, trees and sites".

Legally compliant/duty to co-operate - don't know.
Sound: the Plan fails to connect trees with the Historic Environment; historic trees are also finite resources (NPPF irreplaceable habitat) for which management and protection is needed to ensure their importance is retained.

The reference to achieving net gains in tree cover is welcome.
Policies in the Plan need to be in place to secure this objective.

The specific reference to trees and hedgerows is welcome and appropriate.

For consistency, 3c should probably add ", ancient" before "and veteran trees".

The inclusion of B and 3c referencing irreplaceable habitats, including ancient woodland and ancient or veteran trees, is welcome and appropriate. (For consistency, 3c should probably add ", ancient" before "and veteran trees".)

Suggest penultimate sentence amended to:
"A "valued" tree should include those determined using the criteria contained in British Standard 5837. Trees under 75mm in stem diameter and under 1.5m above ground level may be valued trees where they provide opportunities for succession planning for existing trees and/or for naturally regenerating woodland."
N.B. based on original wording which might mistakenly use "and" - the 75mm stem diameter measurement might be AT 1.5m above ground level.

Chichester Tree Wardens (volunteers) do not have access to BS5837 Trees in relation to design, demolition and construction – Code of Practice, but note that it is under review ( https://standardsdevelopment.bsigroup.com/projects/9022-07743#/section ). Based on the classification system we have seen in tree consultants' reports, trees may be "valued" by our local community and wildlife that are considered appropriate to fell under traditional arboricultural practice. (We have a recent example of a change in approach for a development proposal as a result of our and CDC's Environment representations.) We don't know whether changing attitudes to "over mature" trees and biodiversity will be picked up in the BS5837.
Additionally, trees under 75mm stem diameter at 1.5m above ground level may be significant - self-sown baby trees are the trees of the future, biosecure from local genetic stock, needing little maintenance, with established soils and mycorrhizal connections, and more likely to thrive than an equivalent planted from nursery stock. They offer an important opportunity to naturally regenerate trees and woodland. (Their omission from BS5837 is probably more one of practicality - the impossibility of listing/assessing every baby tree individually - but their presence generally as habitat/future stock is important.)

Additional Background paragraph needed to require a Trees and Woodland Strategy to be prepared by CDC, subjected to public consultation, and adopted as a Supplementary Planning Document that will make it a material planning consideration, so as to enable delivery of the net gain in tree cover aspect of Strategic Objective 2 and ensure that the spatial distribution of that net gain reflects the aspirations of the Plan as a whole.
I do not know how best to word/include this.

Legally compliant/duty to co-operate - don't know.
Sound: Strategic Objective 2 (following para. 2.51) includes to achieve net gains in tree cover, which we have supported in this Submission Draft. This cannot be achieved without an understanding of existing tree cover and how that differs across the Local Plan area (both in different rural landscapes and different urban communities - typically higher tree cover is found in more affluent/expensive areas and lower tree cover correlates to higher deprivation and, in our experience of Chichester City parish area, less protection/tree planting). The aspiration for greater tree cover is not mentioned in either Background paragraphs 4.41 or 4.42 or Policy NE8, where it needs to be (nor I think in other policies where there are references to trees, hedgerows and woodland).
Natural England’s National Framework of Green Infrastructure Standards (launched January 2023, referenced in one line at para. 6.81 of this Plan) includes an Urban Tree Canopy Cover (UTCC) Standard intended to increase UTCC “by an agreed percentage based on a local defined baseline and considering local needs, opportunities and constraints” (page 17, https://designatedsites.naturalengland.org.uk/GreenInfrastructure/downloads/Design Guide - Green Infrastructure Framework.pdf ). A Trees and Woodland Strategy Toolkit ( https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/#1669729165445-ac6bc64e-229e ) was published in December 2022 by DEFRA with the Forestry Commission and the Tree Council (the charity that runs the national volunteer Tree Warden scheme of which Chichester Tree Wardens are part) pursuant to the England Trees Action Plan published in May 2021.
West Sussex County Council has a West Sussex Tree Plan, published December 2020, which focusses on WSCC-owned trees but "also seeks to influence how the wider tree resource within the County is managed and improved" (para. 1.3).
In the absence of CDC resources having already been invested in a Tree and Woodland Strategy (TaWS) for the Plan Area to achieve the tree cover aspirations of Strategic Objective 2, the Plan needs to make provision for a TaWS to be prepared, subjected to public consultation, and adopted as a Supplementary Planning Document that will make it a material planning consideration. The TaWS should ensure that the spatial distribution of net gain in tree cover reflects the aspirations of the Plan as a whole. (The amenity value/ecosystem services of trees, including woodlands and hedgerows, vary according to where they are growing - rural trees are no substitute for trees in urban areas where they improve the lives of many people on a daily basis.)

1. New criteria: “Development sites that include existing large tree(s) should demonstrate succession planning for similarly large trees so as to sustain the landscape impact of trees and achieve net gain in on-site tree cover.”
2. Edit NE8, para. 4 “proposals will be required to plant two trees for each one lost through development” to “proposals will be required to deliver net gain in tree cover for each tree lost through development 5 years after felling”.
3. Add “All major development proposals will be required to provide new woodland areas for public recreational use related to the development.”
4. Add to NE8, para 9. “Developments will be expected to retain existing and planted trees for the long term and demonstrate succession planning.”
5. Add to NE8, para. 10 “All trees planted on site will be required to demonstrate responsible biosecurity, such as Plant Healthy certification ( https://planthealthy.org.uk/plant-health-alliance ) or similar.
6. Delete "major" in NE8, para. 6 and add "(off-site, ideally nearby, if no opportunity onsite)".
7. Add words along the lines of "including the local Trees and Woodland Strategy" to the final policy sentence (our Objection under Background para. 4.42 refers).

Legally compliant/duty to co-operate - don't know.
Sound: Chichester Tree Wardens broadly support Policy NE8 Trees, Hedgerows and Woodlands, subject to our comments on Background paragraphs 4.41 and 4.42, particularly the need for CDC to prepare a Trees and Woodland Strategy for the Plan Area as a Supplementary Planning Document to plan for the net gain in tree cover that forms part of Strategic Objective 2. However, there are some specific threats to tree cover (and therefore the delivery of the Plan) which are not addressed:
• Loss of tree cover due to failure/removal of large trees and constraints in replacement planting (including lack of space for a tree which could grow to a comparable size and the encroachment of utilities into rooting areas);
• Where large trees are lost, replacement trees do not compensate for loss of tree cover – the 2-for-1 policy in paragraph 4 will not deliver a net gain in tree cover for decades, if at all;
• Increasing recreational pressure on existing woodland from a growing population and a flight to tree-conditioned shade in hot summers (compaction of forest floors risks premature decline/death of trees);
• Existing and new trees included in development proposals not being retained in the long term, despite their importance for planning objectives, as a result of the convention of only requiring replacement if a new tree fails within the first 5 years of planting;
• Biosecurity risks.
ALSO to avoid widening inequalities of place, all developments should be required to provide street tree planting (off-site, ideally nearby, if no opportunity onsite), not just "major" developments (NE8, para. 6).

Ideally this and similar paragraphs (e.g. 6.24) which refer to trees for shade would recognise the additional cooling benefit of trees due to transpiration - the release of water from leaves, effectively creating a natural air conditioner.

Ideally this and similar paragraphs (e.g. 6.23, but there may be others) which refer to trees for shade would recognise the additional cooling benefit of trees due to transpiration - the release of water from leaves, effectively creating a natural air conditioner.

Ideally this and similar paragraphs (e.g. 6.23, but there may be others) which refer to trees for shade would recognise the additional cooling benefit of trees due to transpiration - the release of water from leaves, effectively creating a natural air conditioner.

See also representations on Policy NE8 Trees, Hedgerows and Woodlands.