Issues and Options Document

The Government has recently published it's draft revision of the National Planning Policy Framework (NPPF) and this document includes a significant in paragraph 173, where it states that .."development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons...." This is a clear direction of travel in Government planning policy and gives much stronger protection to ancient woodland than that given by Policy DM25 in your Development Management Plan. We would therefore like to see your Local Plan state that development affecting ancient woodland will only be permitted if there are wholly exceptional reasons.

We broadly support the statements in the existing policy DM25 on the need for more woodland creation and the locations in which this may be prioritised; for example adjacent to areas of ancient woodland and as part of green infrastructure in new housing development.

We would like to suggest that you also look at using access standards to determine how much new woodland may need to be created. The Woodland Trust has an Access to Woodland Standard whiich aspires that everyone should have a small wood of at least two hectares in size within 500 metres of their home and a larger wood of at least 20 hectares within 4km of their home. Currently our statistics show that 20 per cent of people in Rochford have a small wood within 500 metres of their home, which is slightly above the national average but less than in some neighbouring districts. We would be happy to discuss the access standard with your officers in more detail, if it is something you wish to consider for inclusion in your local plan.

Policy DM29 is fine in so far as it goes but it is quite a short policy which only specifically refers to NO2 pollution, whereas there is much more concern recently about the impact of other pollutants such as particulates on human health.

We are also aware of an increasing body of research which shows the role which trees can play in helping to absorb pollutants and hence improve air quality, if the trees are of the right species and planted in the right locations: for example at busy road junctions. We have a report on this subject which can be found on our website at http://www.woodlandtrust.org.uk/publications/2012/04/urban-air-quality .

We have referred in our comments in the trees and woodland section to the need to strengthen ancient woodland policy in your new Local Plan, in line with emerging policies in the draft revised NPPF.

We would also like you to consider the role which trees and woods can play in improving water quality and lowering flood risk. There is a polcy on flood risk in your exisitng Core Strategy (ENV2) which does not mention a role for green infrastructure, trees or woods but there is increasing reseach on this subject. Some of this is summarised in our report "Stemming the Flow" which can be found on our website at http://www.woodlandtrust.org.uk/publications/2014/05/stemming-the-flow/