Chichester Local Plan 2021 - 2039: Proposed Submission

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.

Please note that as a Non-Ministerial Government Department, we provide no opinion supporting or objecting to planning applications or local plans including their soundness or legal compliance.

Rather we are including advice and information that we advise the Council consider to ensure their pre-submission local plan avoids potential impacts and promote enhancements/expansion as part of the proposed local plan regarding trees and woodland, including ancient woodland. We acknowledge that the purpose of Regulation 19 consultations does not usually extend to making substantial changes which are not related to soundness so we offer our advice as helpful guidance to ensure the local plan takes every opportunity to secure the protection, enhancement and expansion of Chichester’s valuable trees and woodlands to comply with planning policy, good practice and to make the most of the many benefits they provide to the environment, local economy and community.

Overall Comments
Ancient woodlands, veteran and ancient trees are irreplaceable habitats, and it is essential that they are considered appropriately to avoid any direct or indirect effects that could cause their loss or deterioration, in line with Government Standing Advice. Ancient Woodland has very high potential ecological value and should act as integral focal points, alongside other locally and nationally designated sites, as part of delivering landscape scale nature recovery.

Any development or plan that include these irreplaceable habitats on or near to the site should aim to deliver high standards of net gains and ecological connectivity that supports wider ecological networks, in line with good practice. This will also be a requirement as part of the local nature recovery strategies being driven by the Environment Act 2021 and we advise that plans should anticipate this to maximise environmental benefits to contribute to reversing the national trend of ecological decline as part of broader nature recovery networks. The Local Plan should be considered as a crucial and timely opportunity to secure significant and strategic, plan-led environmental gains due to their scope and scale, particularly given the timescales of development being influenced that coincide with UK Government commitments regarding halving emissions and protecting 30% of nature by 2030, towards a net-zero carbon and nature positive economy.

The development strategy should prioritise the protection of trees and woodlands with the highest priority being given to ancient woodland, ancient and veteran trees as individual habitats and as part of wider ecological networks.

Site Allocation comments:

Policy A7 Land at Shopwyke (Oving Parish)
Site specific considerations could recognise the existing trees, hedgerows and woodland and prioritise their protection, enhancement and expansion as part of biodiversity net gains. Acoustic screening referred to could also use trees to make the most of multi-functional benefits they bring.

Policy A8 Land East of Chichester
We welcome efforts to bolster the existing woodland and the proposed strategic wildlife corridor to the East and the enhancements that development could bring.

Policy A11 Highgrove Farm, Bosham
Bolster planting to North, South and East is welcome. This policy could be improved by requiring bolster planting to the West as well, where there appears to be an existing line of trees, making it well placed to further contribute to wider connectivity with existing and additional planting.

Policy A12 Chidham and Hambrook and Policy A13 Southbourne Broad Location for Development
We note that more detailed proposals will emerge as part of a Neighbourhood plans. We would like to highlight that this area contains some parcels of ancient woodland which is an irreplaceable and high priority habitat according to the NPPF and Government Policy (see attached Annex and below for more guidance on this). The policy could be improved by highlighting its importance and high priority as part of efforts to protect, enhance, expand and connect habitats as part of a wider ecological network and the strategic wildlife corridor. Developments within this area could contribute pockets of woodland and linear planting to help connect existing trees and woodland as part of a mosaic of habitats throughout the wildlife corridor and wider area. The requirement to ensure development does not have an adverse impact on the strategic wildlife corridor is also welcome but could be strengthened by requiring developments to significantly contribute to its enhancement, expansion and connectivity including with green infrastructure provided by development

Policy A14 Land West of Tangmere
The requirement for significant levels of green infrastructure is welcome. This policy could be strengthened by requiring development to retain and bolster existing hedgerows and trees wherever possible.

Policy A16 Goodwood Motor Circuit and Airfield and Policy A17 Development within the vicinity of Goodwood Motor Circuit and Airfield
This policy could be improved by recognising the significant amount of ancient woodland and non-ancient woodland to North of the area. We would encourage any development in the area to protect, enhance and expand the woodland in the area as part of delivering net gains.

Policy A21 Land east of Rolls Royce
This area contains areas of existing trees, hedgerow and woodland which are not currently mentioned by the policy. We would encourage any development to be sensitive to this and provide additional planting where possible.

Overarching comments
We would welcome the consideration of incorporating large and small pockets of multi-functional woodland as part of green infrastructure provision for development, particularly given the relatively low proportion of woodland found throughout the District, and the benefits this can have as ‘stepping stones’ between habitats as part of the Local Plan’s welcome vision of strategic wildlife corridors.

We also encourage the Council to appraise the plan against the following advice to maximise the benefits from protection, enhancement and expansion of woodlands, trees and connectivity throughout the District:

Additional improvements to consider

• Tree/hedgerow removal is considered as a last resort but where it is justified, we advise that developments can aim to deliver no net deforestation to help encourage development that provides an overall environmental gain. Ie where trees are required to be removed, additional tree planting will be made to compensate for this loss and we would advise that additional planting should be made to help compensate for the loss of habitat in the time it takes for new trees to mature.
• Long term management and maintenance of planted trees and woodland creation to give them every chance to becoming established and where trees do fail, they are replaced
• A minimum standard for tree canopy cover for new developments (e.g. for large-scale developments) as it provides a targetable level of green infrastructure in relation to trees for the numerous ecosystem services they provide.
• Precautions should be incorporated into any woodland design and tree planting to ensure that habitat creation is established successfully and that potential impacts from deer are managed on site and in the surrounding area as appropriate. See here for further guidance that should be followed for managing impacts from deer as part of woodland creation and tree planting: https://www.gov.uk/government/publications/woodland-creation-and-mitigating-the-impacts-of-deer/woodland-creation-and-mitigating-the-impacts-of-deer Some good practice advice is also provided in Appendix 1 of this letter.
• We advise that any tree planting should meet the following:
o Trees should be healthy and good practice biosecurity should be followed to prevent the risk of spreading pests and disease, in line with Government advice: https://www.gov.uk/government/collections/tree-pests-and-diseases. More information on the plant healthy can be found at: Welcome to Plant Healthy - Plant Healthy
o Created or restored habitat should be managed in perpetuity in line with a robust management plan that follows good practice to ensure assumed benefits of created habitats are delivered in practice (see Standing Advice referred to on page 1). We recommend meeting the UK Forestry Standard to demonstrate this.
• To help mitigate climate and support local economy would urge council to develop local plan policy that makes use of locally sourced timber. This has multiple benefits as it can help store carbon within development, reduce impact from transportation, reduce embodied carbon from alternative materials and support local economies and communities.
• Where developments incorporate District Heating, consider locally and sustainably sourced wood-fuels for the benefits this can have for renewable energy and towards a local, circular economy
• Use tree planting as part of nature based solutions for managing flood risk as well as other multi-functional benefits from green infrastructure as part of any development (e.g. Trees and woodlands provide £400 million of value in flood protection)
• We encourage the Council to refine their strategy to trees and woodlands using the recently launched ‘Trees and Woodland Strategy Toolkit’ available here: https://treecouncil.org.uk/what-we-do/science-and-research/tree-strategies/ to design and deliver a local tree strategy to harness the long-term benefits that trees can bring to local communities. The local plan should be developed with tree/woodlands in mind as an integral part, alongside other supplementary strategies for the environment including biodiversity, green infrastructure, nature recovery and climate change.

Key guidance regarding trees, woodland and development

Ancient woodlands, ancient trees and veteran trees are irreplaceable habitats. Paragraph 180(c) of the NPPF sets out that development resulting in the loss or deterioration of irreplaceable habitats should be refused unless there are wholly exceptional reasons and a suitable compensation strategy exists. In considering the impacts of the development on Ancient Woodland, Ancient and Veteran trees, the planning authority should consider direct and indirect impacts resulting from both construction and operational phases.

Please refer to Natural England and Forestry Commission joint Standing Advice for Ancient Woodland and Ancient and Veteran Trees, updated in January 2022. The Standing Advice can be a material consideration for planning decisions, and contains advice and guidance on assessing the effects of development, and how to avoid and mitigate impacts. It also includes an Assessment Guide which can help planners assess the impact of the proposed development on ancient woodland or ancient and veteran trees in line with the NPPF.

Existing trees should be retained wherever possible, and opportunities should be taken to incorporate trees into development. Trees and woodlands provide multiple benefits to society such as storing carbon, regulating temperatures, strengthening flood resilience and reducing noise and air pollution.[1] Paragraph 131 of the NPPF seeks to ensure new streets are tree lined, that opportunities should be taken to incorporate trees elsewhere in developments, and that existing trees are retained wherever possible. Appropriate measures should be in place to secure the long-term maintenance of newly planted trees. The Forestry Commission may be able to give further support in developing appropriate conditions in relation to woodland creation, management or mitigation.

Biodiversity Net Gain (BNG): Paragraph 174(d) of the NPPF sets out that planning (policies and) decisions should minimise impacts on and provide net gains for biodiversity. Paragraph 180(d) encourages development design to integrate opportunities to improve biodiversity, especially where this can secure net gains for biodiversity. A requirement for most development to deliver a minimum of 10% BNG is expected to become mandatory from November 2023. The planning authority should consider the wide range of benefits trees, hedgerows and woodlands provide as part of delivering good practice biodiversity net gain requirements. Losses of irreplaceable or very high distinctiveness habitat cannot adequately be accounted for through BNG.