New Local Plan: Spatial Options Document 2021

We agree that important habitats should be protected. We are happy with having a hierachy of levels of protection, so long as irreplaceable habitats such as ancient woodland and ancient/veteran trees are given the highest level of protection. The protection should be no less strong than that provided by paragraph 175c of the NPPF, which states that any development affecting these habitats should be "wholly exceptional". We would also like to see appropriate levels of buffering (which should be at least 50 metres) provided for development adjacent to ancient woodland, as set out in our Planners' Manual on ancient woodland and ancient trees. https://www.woodlandtrust.org.uk/publications/2019/06/planners-manual-for-ancient-woodland/

We have looked at the site allocations within the plan and we have identified that a number of the allocations have adverse impacts on ancient woodland. We have listed these in an email to your consultation email address and we hope you will consider removing these allocations from the plan.

We would like to see the plan ask for 20% biodiversity net gain, rather than the 10% likely to be required when the Environment Bill becomes law. At a time of biodiversity and climate emergency, we believe ambition is needed to ensure that significant gains in biodiversity are delivered as part of new development. We also believe that trees and woods have a crucial role to play in tackling both emergencies and delivering a wide range of benefits in addition to biodiversity enhancement. Ideally we would like to see biodiversity net gain delivered on site or, if this is genuinely not possible, then as near as possible to the development site.

We are not opposed to any of the three options in principle. In line with the Lawton principles, it is important that new green infrastructure created as part of development links up with existing areas of GI to form an integrated and well planned network and that it contains areas of natural greenspace, such as woodland, so as to enhance biodiversity. It can be particularly beneficial to create new woodland by natural regeneration, adjacent to existing ancient woods, as this allows migration of species over time into the new woodland.

The Woodland Trust's Emergency Tree Plan, which is available on the publications section of our website at www.woodlandtrust.org.uk set out how trees and woods can make an important contribution to tackling the climate emergency, through both mitigation and adaptation, and the biodiversity emergency. New development offers an opportunity for planting of new trees and woods as part of GI and we would like to see your Local Plan set a target for a minimum of 30% tree canopy cover on any development site. A number of councils have set ambitious tree canopy cover targets, including Bedford and Central Bedfordshire who have gone for 30% and the former Wycombe Council (now part of Bucks unitary council) who went for 25%.

An alternative method of calculating the need for trees and woods is to use an access standard, such as the Woodland Trust's Accesss to Woodland Standard, which aspires that everyone should have a small wood of at least 2ha in size within 500m of their home and a larger wood of at least 20ha within 4km of their home. This standard is designed to be complementary to Natural England's Natural Greenspace Standard and natural greenspace does, of course, include woodland.

We would like to see tree and woodland cover in new development include both small areas of new woodland, where appropriate, and also individual trees or groups of trees in streets and on areas of greenspace in new housing estates. The Government has stated its intention to legislate to require that all streets in new housing developments should be tree lined, recognising the wide range of benefits which street trees can provide to local people.

We have provided a separate submission by email which includes a table setting out some of your site allocations, mainly ones in Hockley and Rayleigh, that we believe may pose a threat to ancient woodland or to ancient veteran trees. We would like you consider either removing these from the plan or, where possible, putting in appropriate buffers (of at least 50 metres).

We have identified some sites which are proposed for development in Rayleigh which we believe pose a threat to areas of ancient woodland and/or to ancient or veteran trees. We have listed these in a separate email and we would ask that you either remove these from the plan or consider appropriate buffering, as appropriate.

We welcome inclusion of a reference to the RSPB's important wetland site in the vision but we would also like you to consider including a reference to the importance of trees and woods, planted in the right locations, for providing a wide range of benefits for local people and for wildlife and, of course, contributing to mitigation of and adaptation to climate change.

It is good to see a section in the objectives (20 to 23) on climate change mitigation and adaptation and enhancement of the natural environment. You could refer in these objectives to the fact that it is widely recognised that there are two emergencies facing the planet: a climate emergency and a biodiversity emergency and that these are closely interlinked. You could refer to the important role which trees and woods can play in helping to tackle both emergencies: for example trees can sequester carbon (mitigation) and reduce midsummer urban temperatures and help prevent or alleviate surface water flooding (adaptation).

It also seems odd that, having made climate change a strategic objective, there is no specific policy on it later in the plan. Perhaps you could consider either including a separate climate change policy or having it as a theme which is mentioned frequently in other policies? Many councils have a separate policy in their plan on trees and woods, which enables them to set out the important benefits which they provide.

I have made some submissions to your local plan consultation on behalf of the Woodland Trust, using your online consultation portal.

I flagged up in our online submission that we have concerns about the impact which some of your site allocations may have on ancient woods or on ancient/veteran trees and I said I would send information on these separately by email, so see attached table. You can see from the table that in some cases we are concerned about proximity to ancient woods or trees and in such cases we would ask for a buffer strip to be included of at least 50 metres before development is allowed to proceed. In other cases, we believe there may be actual loss of habitat and so we would urge that these allocations be withdrawn or significantly amended.

We have guidance on ancient woodland and ancient/veteran trees in our Planners Manual which can be found on our website at https://www.woodlandtrust.org.uk/publications/2019/06/planners-manual-for-ancient-woodland and we would ask that you refer to this document when considering our submissions regarding these site allocations.

[see attached document - list of sites of concern with proximity to ancient woodland (within or adjacent) as follows:]

CFS068 Land at Lower Wyburns farm, to the south of Daws Heath Road, Rayleigh Rayleigh Adjacent WT Lower Wyburns (grid reference: TQ812895)
CFS023 Land north and east of Malvern Road, Hockley Hockley Adjacent Beckney Wood ASNW (grid reference: TQ8468693935)
CFS062 Land north of Lambourne Hall Road, Canewdon Canewdon Adjacent WT Paddock Copse (grid reference: TQ906946)
CFS134 Land between Eastwood Rise and Rayleigh Avenue, Eastwood Rayleigh Adjacent New England Wood ASNW (grid reference: TQ8336190291)
CFS160 Northlands Farm, 65 High Road, Hockley Hockley Within Hockley Woods ASNW (grid reference: TQ8256791923)
CFS045 Belchamps Scout Site, Holyoak Lane, Hawkwell Hawkwell Within Hockley Woods ASNW (grid reference: TQ8412091789)
GF01 Land north west of Hockley Station Hockley Adjacent Maryland’s Wood ASNW (grid
reference: TQ8375192993)
CFS064 Land north and east of Folly Chase, Hockley Hockley Adjacent Betts Wood ASNW (grid reference: TQ8331992870)
COL20 Civic Suite, Hockley Road, Rayleigh Rayleigh Within Veteran Common Sycamore (ATI no: 11502) at grid reference: TQ80849087

I have made some submissions to your local plan consultation on behalf of the Woodland Trust, using your online consultation portal.

I flagged up in our online submission that we have concerns about the impact which some of your site allocations may have on ancient woods or on ancient/veteran trees and I said I would send information on these separately by email, so see attached table. You can see from the table that in some cases we are concerned about proximity to ancient woods or trees and in such cases we would ask for a buffer strip to be included of at least 50 metres before development is allowed to proceed. In other cases, we believe there may be actual loss of habitat and so we would urge that these allocations be withdrawn or significantly amended.

We have guidance on ancient woodland and ancient/veteran trees in our Planners Manual which can be found on our website at https://www.woodlandtrust.org.uk/publications/2019/06/planners-manual-for-ancient-woodland and we would ask that you refer to this document when considering our submissions regarding these site allocations.

[see attached document - list of sites of concern with proximity to ancient woodland (within or adjacent) as follows:]

CFS068 Land at Lower Wyburns farm, to the south of Daws Heath Road, Rayleigh Rayleigh Adjacent WT Lower Wyburns (grid reference: TQ812895)
CFS023 Land north and east of Malvern Road, Hockley Hockley Adjacent Beckney Wood ASNW (grid reference: TQ8468693935)
CFS062 Land north of Lambourne Hall Road, Canewdon Canewdon Adjacent WT Paddock Copse (grid reference: TQ906946)
CFS134 Land between Eastwood Rise and Rayleigh Avenue, Eastwood Rayleigh Adjacent New England Wood ASNW (grid reference: TQ8336190291)
CFS160 Northlands Farm, 65 High Road, Hockley Hockley Within Hockley Woods ASNW (grid reference: TQ8256791923)
CFS045 Belchamps Scout Site, Holyoak Lane, Hawkwell Hawkwell Within Hockley Woods ASNW (grid reference: TQ8412091789)
GF01 Land north west of Hockley Station Hockley Adjacent Maryland’s Wood ASNW (grid
reference: TQ8375192993)
CFS064 Land north and east of Folly Chase, Hockley Hockley Adjacent Betts Wood ASNW (grid reference: TQ8331992870)
COL20 Civic Suite, Hockley Road, Rayleigh Rayleigh Within Veteran Common Sycamore (ATI no: 11502) at grid reference: TQ80849087

I have made some submissions to your local plan consultation on behalf of the Woodland Trust, using your online consultation portal.

I flagged up in our online submission that we have concerns about the impact which some of your site allocations may have on ancient woods or on ancient/veteran trees and I said I would send information on these separately by email, so see attached table. You can see from the table that in some cases we are concerned about proximity to ancient woods or trees and in such cases we would ask for a buffer strip to be included of at least 50 metres before development is allowed to proceed. In other cases, we believe there may be actual loss of habitat and so we would urge that these allocations be withdrawn or significantly amended.

We have guidance on ancient woodland and ancient/veteran trees in our Planners Manual which can be found on our website at https://www.woodlandtrust.org.uk/publications/2019/06/planners-manual-for-ancient-woodland and we would ask that you refer to this document when considering our submissions regarding these site allocations.

[see attached document - list of sites of concern with proximity to ancient woodland (within or adjacent) as follows:]

CFS068 Land at Lower Wyburns farm, to the south of Daws Heath Road, Rayleigh Rayleigh Adjacent WT Lower Wyburns (grid reference: TQ812895)
CFS023 Land north and east of Malvern Road, Hockley Hockley Adjacent Beckney Wood ASNW (grid reference: TQ8468693935)
CFS062 Land north of Lambourne Hall Road, Canewdon Canewdon Adjacent WT Paddock Copse (grid reference: TQ906946)
CFS134 Land between Eastwood Rise and Rayleigh Avenue, Eastwood Rayleigh Adjacent New England Wood ASNW (grid reference: TQ8336190291)
CFS160 Northlands Farm, 65 High Road, Hockley Hockley Within Hockley Woods ASNW (grid reference: TQ8256791923)
CFS045 Belchamps Scout Site, Holyoak Lane, Hawkwell Hawkwell Within Hockley Woods ASNW (grid reference: TQ8412091789)
GF01 Land north west of Hockley Station Hockley Adjacent Maryland’s Wood ASNW (grid
reference: TQ8375192993)
CFS064 Land north and east of Folly Chase, Hockley Hockley Adjacent Betts Wood ASNW (grid reference: TQ8331992870)
COL20 Civic Suite, Hockley Road, Rayleigh Rayleigh Within Veteran Common Sycamore (ATI no: 11502) at grid reference: TQ80849087