Rother Local Plan 2020-2040 (Regulation 18)
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Rother Local Plan 2020-2040 (Regulation 18)
102. Are there any alternative or additional points the Council should be considering?
Representation ID: 26077
Received: 23/07/2024
Respondent: Woodland Trust
We recommend adding reference to meeting deficiencies in tree equity in point ii.
We recommend adding reference to access to natural greenspace, and in particular, access to woodland.
The Woodland Trust has developed a Woodland Access Standard to complement the Accessible Natural Green Space Standard. This recommends that:
– That no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size.
– That there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round trip) of people’s homes.
We recommend adding reference to meeting deficiencies in tree equity in point ii.
We recommend adding reference to access to natural greenspace, and in particular, access to woodland.
The Woodland Trust has developed a Woodland Access Standard to complement the Accessible Natural Green Space Standard. This recommends that:
– That no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size.
– That there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round trip) of people’s homes.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
150. Are there any alternatives or additional points the Council should be considering?
Representation ID: 26082
Received: 23/07/2024
Respondent: Woodland Trust
The policy is silent on the impact of extensions on existing trees. We recommend a presumption in
favour of the retention and enhancement of existing trees, woodland, and hedgerow cover on
development sites. We further request that where there is an unavoidable loss of trees on site, that an appropriate number of suitable replacement trees will be required to be planted.
We commend the wording used in the Rushmoor SPD on Home improvements and extensions (December 2019): "Wherever possible, development should retain garden trees and landscaping features that make a positive contribution to the residential environment. As well as providing a pleasant residential environment, trees and gardens contribute towards biodiversity and health and well-being and can also help screen or soften the visual impact of a new extension and help to integrate it with the surroundings."
The policy is silent on the impact of extensions on existing trees. We recommend a presumption in
favour of the retention and enhancement of existing trees, woodland, and hedgerow cover on
development sites. We further request that where there is an unavoidable loss of trees on site, that an appropriate number of suitable replacement trees will be required to be planted.
We commend the wording used in the Rushmoor SPD on Home improvements and extensions (December 2019): "Wherever possible, development should retain garden trees and landscaping features that make a positive contribution to the residential environment. As well as providing a pleasant residential environment, trees and gardens contribute towards biodiversity and health and well-being and can also help screen or soften the visual impact of a new extension and help to integrate it with the surroundings."
Comment
Rother Local Plan 2020-2040 (Regulation 18)
181. Are there any alternatives or additional points the Council should be considering?
Representation ID: 26103
Received: 23/07/2024
Respondent: Woodland Trust
We recommend these additions
- explicit protection for ancient woodland and ancient / veteran trees
- setting a presumption for retention of all existing trees, unless the applicant can demonstrate necessity
- setting a minimum tree canopy cover target for development sites, to deliver the policy goal of enhanced tree cover
- setting a replacement ratio greater than 1:1 where trees are unavoidably lost to development
Such a policy will also make a positive contribution to biodiversity net gain and nature recovery, as well as better reflecting the requirements of the NPPF.
We recommend these additions
- explicit protection for ancient woodland and ancient / veteran trees
- setting a presumption for retention of all existing trees, unless the applicant can demonstrate necessity
- setting a minimum tree canopy cover target for development sites, to deliver the policy goal of enhanced tree cover
- setting a replacement ratio greater than 1:1 where trees are unavoidably lost to development
Such a policy will also make a positive contribution to biodiversity net gain and nature recovery, as well as better reflecting the requirements of the NPPF.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Proposed Policy ENV5: Habitats and Species
Representation ID: 26111
Received: 23/07/2024
Respondent: Woodland Trust
Support this policy approach, including the specification of minimum buffers and impact assessments for development close to ancient woodland or ancient & veteran trees. This policy should be referenced in LAN2.
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.
Support this policy approach, including the specification of minimum buffers and impact assessments for development close to ancient woodland or ancient & veteran trees. This policy should be referenced in LAN2.
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.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
11.56
Representation ID: 26114
Received: 23/07/2024
Respondent: Woodland Trust
Ancient woodland is greatly at risk from ammonia pollution. We recommend therefore adding specific requirements that additional screening will be required of all ammonia-emitting developments, such as intensive livestock units, within 5km of an ancient woodland site, with a detailed ‘Ancient Woodland Nitrogen Impact Assessment’ of the ancient woodland of concern. This will need to demonstrate that there will be no deterioration or impacts as a result of the contributions from this development.
Ancient woodland is greatly at risk from ammonia pollution. We recommend therefore adding specific requirements that additional screening will be required of all ammonia-emitting developments, such as intensive livestock units, within 5km of an ancient woodland site, with a detailed ‘Ancient Woodland Nitrogen Impact Assessment’ of the ancient woodland of concern. This will need to demonstrate that there will be no deterioration or impacts as a result of the contributions from this development.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
196. Specifically, what are your views on the Council requiring an impact assessment for any development proposed within 25 metres of Ancient Woodland?
Representation ID: 26115
Received: 23/07/2024
Respondent: Woodland Trust
Strongly support this policy. It is best practice to require an assessment of impact in order to determine the appropriate mitigation measures, including whether a larger buffer zone is required.
Ancient woodland is greatly at risk from ammonia pollution. We recommend therefore adding specific requirements that additional screening will be required of all ammonia-emitting developments, such as intensive livestock units, within 5km of an ancient woodland site, with a detailed ‘Ancient Woodland Nitrogen Impact Assessment’ of the ancient woodland of concern.
Strongly support this policy. It is best practice to require an assessment of impact in order to determine the appropriate mitigation measures, including whether a larger buffer zone is required.
Ancient woodland is greatly at risk from ammonia pollution. We recommend therefore adding specific requirements that additional screening will be required of all ammonia-emitting developments, such as intensive livestock units, within 5km of an ancient woodland site, with a detailed ‘Ancient Woodland Nitrogen Impact Assessment’ of the ancient woodland of concern.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
195. Are there any alternatives or additional points the Council should be considering?
Representation ID: 26116
Received: 23/07/2024
Respondent: Woodland Trust
We recommend adding reference to ancient woodland protection and protection for ancient trees to LAN2 to ensure a robust and consistent approach throughout the local plan.
We recommend adding reference to ancient woodland protection and protection for ancient trees to LAN2 to ensure a robust and consistent approach throughout the local plan.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
194. What are your views on the Council's proposed policy on sites protected for their habitats and species?
Representation ID: 26119
Received: 23/07/2024
Respondent: Woodland Trust
Ancient woodland, and ancient & veteran trees outside woods, form a uniquely valuable and irreplaceable habitat. The High Weald has more ancient woodland than the rest of England. It is vital that local plans take especial care to include and uphold policies to protect ancient woodland.
We strongly welcome the specific reference to ancient woodland and ancient & veteran trees.
We welcome the recognition given to the importance of ancient woodland and the role that local planning policy plays in safeguarding this irreplaceable natural asset. Ancient woodland is a precious habitat that should be protected and managed in a sustainable way to maximise its wildlife, landscape and historical value.
Ancient woods are irreplaceable. They are our richest terrestrial wildlife habitats, with complex ecological communities that have developed over centuries, and contain a high proportion of rare and threatened species, many of which are dependent on this habitat. Ancient woods are reservoirs of biodiversity, but because the resource is limited and highly fragmented, they and their associated wildlife are particularly vulnerable.
The High Weald has more ancient woodland than the rest of England. It is vital that local plans in this sub region take especial care to include and uphold policies to protect ancient woodland.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
Proposed Policy ENV7: Environmental Pollution
Representation ID: 26121
Received: 23/07/2024
Respondent: Woodland Trust
We welcome the inclusion of the impacts of pollution on biodiversity and the environment, as well as on human health and well-being. We welcome the guidance in 11.95 on the positive role played by trees in mitigating air pollution.
We welcome the inclusion of the impacts of pollution on biodiversity and the environment, as well as on human health and well-being. We welcome the guidance in 11.95 on the positive role played by trees in mitigating air pollution.
Comment
Rother Local Plan 2020-2040 (Regulation 18)
200. Are there any alternatives or additional points the Council should be considering?
Representation ID: 26124
Received: 23/07/2024
Respondent: Woodland Trust
Given the recognition of the valuable role played by trees in mitigating air pollution, we recommend strengthening the policy with reference to nature-based solutions.
eg in the introductory paragraphs, the wording could be expanded to read " Developments should put good design first to minimise the need for mitigation measures, including maximising the use of nature-based solutions."
Given the recognition of the valuable role played by trees in mitigating air pollution, we recommend strengthening the policy with reference to nature-based solutions.
eg in the introductory paragraphs, the wording could be expanded to read " Developments should put good design first to minimise the need for mitigation measures, including maximising the use of nature-based solutions."
