Sites and Policies Plan Consultation Draft

Comment ID 3326881//2
Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM10 View all on this section
Respondent Deleted User View all by this respondent
Response Date 08 Apr 2013
Comment

Policy DM10 Trees

1.    Whilst we are pleased to see the first bullet point, requiring ‘where practical, the introduction of appropriate tree planting as an integral part of the design and landscaping of new developments’, we would like to see this bullet point expanded to encompass a requirement for larger scale woodland creation in respect of more significant developments as part of developer obligations (section 106 or CIL) via biodiversity offsetting.

 

The Adopted North Somerset Council Core Strategy (April 2012) requires in Policy CS4 (Nature Conservation) that: ‘The biodiversity of North Somerset will be maintained and enhanced by….

(5) promoting native tree planting and well targeted woodland creation, and encouraging retention of trees, with a view to enhancing biodiversity’.

 

In addition, Policy CS9 (Green Infrastructure) of the Adopted Core Strategy states that priority will be given to: ‘the protection and planting of trees in woodlands and urban areas, particularly native trees, for public amenity and climate change mitigation and benefits to biodiversity, health and recreation’.

 

The National Planning Policy Framework (NPPF) supports the need for more habitat creation by stating that: ‘Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure’, (DCLG, March 2012, para 114). Also para 117 states that:  ‘To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan’.

 

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim – ‘Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England’, (Biodiversity 2020: A strategy for England’s wildlife and ecosystems services, DEFRA 2011, p.26). 

 

A reading of these new policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that habitat expansion, like native woodland creation, should form a high priority for this Sites & Policies Plan.

 

 

We would therefore like to see the first bullet point of Policy DM10 amended to (upper case text amendments) : North Somerset Council will require that all development proposals:

·         include, where practical, the introduction of appropriate tree planting AND WOODLAND CREATION as an integral part of the design and landscaping of new development AND DEVELOPER OBLIGATION BIODIVERSITY OFFSETTING’.

 

 

2.    We are disappointed that Policy DM10 does not reiterate the Adopted North Somerset Council Core Strategy’s commitment to protecting ancient woodland and ancient trees in Policy CS4 - ‘The biodiversity of North Somerset will be maintained and enhanced by….3) seeking to protect, connect and enhance important habitats, particularly designated sites, ancient woodlands and veteran trees’.

 

 

Government policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The new National Policy Planning Framework clearly states: “…planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland…" (DCLG, March 2012, para 118).

This NPPF wording should be considered in conjunction with other stronger national policies on ancient woodland -

-       The Government’s policy document ‘Keepers of Time – A statement of Policy for England’s Ancient & Native Woodland’ (Defra/Forestry Commission, 2005, p.10) states: ‘The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland’.

 

-       The Government’s Independent Panel on Forestry states: ‘Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time – A statement of policy for England’s ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.’ (Defra, Final Report, July 2012). This has been endorsed by the response in the recent Government Forestry Policy Statement (Defra Jan 2013): ‘We recognise the value of our native and ancient woodland and the importance of restoring open habitats as well as the need to restore plantations on ancient woodland sites. We, therefore, confirm our commitment to the policies set out in both the Open Habitats Policy and Keepers of Time, our statement of policy for England’s ancient and native woodland’.

-       The Government’s Natural Environment White Paper – The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: ‘The Government is committed to providing appropriate protection to ancient woodlands....’.

 

-       The new Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England’s Wildlife & Ecosystem Services, Defra 2011, see ‘Forestry’ para 2.16) states that – ‘We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site’.

 

-       The SW Forestry Framework (Forestry Commission, 2005) contains a key objective to ‘Protect, improve and manage Ancient Semi-Natural Woodland...”.

 

We would therefore like to see an additional bullet point added to Policy DM10 to reflect Adopted Core Strategy Policy CS4 (new text shown upper case) : North Somerset Council will require that all development proposals:…..

·         Protect important habitats, particularly designated sites, ancient woodlands and veteran trees’.

 

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