Rother Local Plan 2020-2040 (Regulation 18)

Support reflecting the importance of the High Weald in the local plan and ensuring that the goals of the HW AONB management plan and associated policies are suitably reflected. The wording on woodland should be strengthened, given the nationally significant ancient woodland sites within the High Weald.

Support this policy approach, in particular the provision for tree-lined streets, landscaping and SUDS, and the requirement that underground infrastructure should not harm street trees.

Incorporating the requirement for tree-lined streets is welcome. In addition, the local plan should be informed by the Tree Equity approach, which seeks to prioritise urban tree planting where there is the greatest social and environmental need.
The UK Tree Equity scorecard and map assesses urban areas for tree equity out of a total score of 100, identifying the highest priority areas for additional trees. https://uk.treeequityscore.org/map#9/50.85/0.4489

The Woodland Trust does not take a position on housing numbers. We support the objective to encourage the re-use and redevelopment of previously-developed land. Such redevelopment should seek to preserve existing mature trees and protect existing habitats on biodiverse brownfield sites. High density housing should seek to accommodate trees along boundaries, paths and in areas of public space.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development.

Areas of natural woodland, in particular ancient woodland, are vulnerable to pollution, encroachment from development, and habitat fragmentation. It is important that any development is located and designed to avoid damaging ancient woodland, providing buffers for designated sites and protecting connectivity between wildlife habitats. Further information is available in the Trust’s Planners’ Manual for ancient woodland.

Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice. A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance.

The National Planning Policy Framework (NPPF) (paragraph 180c) states: “When determining planning applications, local planning authorities should apply the following principles: …… c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”.

The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

We recognise the intense pressure to identify and bring forward new sites for housing and employment uses. This pressure makes it all the more important that vital protections for ancient woodland and veteran trees are upheld.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

The Woodland Trust objects to ancient woodland areas being included in sites allocated as suitable for development. Where development sites are adjacent to ancient woodland, we recommend that as a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland.
The Ancient Tree Inventory (ATI) for the area may be incomplete. We therefore recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across any sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF (paragraph 186c) for the protection of irreplaceable habitats.

We encourage the inclusion of green infrastructure as part of essential infrastructure and connectivity and taking an area-wide approach to maximise the benefits for nature and people.
We particularly welcome the references to addressing deficits in provision (point ii) and to integrating existing GI into developments (point iii).
We welcome the policy that existing trees, green spaces, and hedges, should be integrated, protected and enhanced in new developments. Integrating trees and green spaces into developments early on in the design process minimises costs and maximises the environmental, social and economic benefits that they can provide.
To achieve ongoing benefits, green infrastructure needs to be protected and maintained. CIL allocations for green infrastructure should include management plans and funding for maintenance. Natural green infrastructure is cost-effective: for example, trees cost less to maintain than regularly-mown turf and have wider biodiversity benefits.