Written evidence submitted by the Woodland Trust (SRI0016)

Introduction

1. The Woodland Trust is the largest woodland conservation charity in the UK, with over 1,200 sites in its care covering over 29,000 hectares. Access to its woods is free. The Woodland Trust has over 500,000 supporters. The Trust wants to see a UK rich in native woods and trees for nature and people. It has three key aims: i) protect ancient woodland which is rare, unique and irreplaceable; ii) restore damaged ancient woodland, bringing precious pieces of our natural history back to life; iii) plant native trees and woods with the aim of creating resilient landscapes for people and wildlife.

2. We welcome the opportunity to respond to this inquiry. We would also welcome the opportunity to give oral evidence in addition to this submission. Please contact Cassie Staines (cassiestaines@woodlandtrust.org.uk) to discuss this or any questions about our written evidence.

Overview

3. In our experience, too often the creation of new roads and the widening of existing roads leads to further fragmentation, loss and deterioration of wildlife habitat, including irreplaceable habitats such as ancient woodland and veteran trees. Our analysis of the schemes supported by the Roads Investment Strategies 1 and 2 shows that in total, 44% of schemes are anticipated to impact ancient woodland and veteran trees.

4. The legal and policy context has changed significantly since the first (and even the second) roads investment strategy. Areas that the RIS needs to address include: the push for net zero, introduction of biodiversity net gain as well as welcome stronger protections for irreplaceable habitats in planning (through the National Planning Policy Framework update in 2018 and commitments made by Government during the passage of the Environment Act). The UK has committed to global targets to protect and improve nature as part of the COP15 negotiations and recognised, through the Environment Act 2021, that maintaining the status quo on environmental protection is not enough if the twin challenges of the nature and climate crises are to be addressed. The Government must make sure that environmental assessment is not just a tick box exercise through Environmental Outcomes Reports process, and ensure that levelling up and access to nature inform the third Investment Strategy.

5. The UK Government should learn from the approach of the Wales Roads Review and others, to ensure its roads investment strategy addresses this changed policy context. It is important to note the important preliminary work by the Roads investment Scrutiny Panel, in particular need for clarity and accountability on decarbonisation of the road network. The Woodland Trust supports the conclusion that biodiversity is still not treated as an investment priority (or indeed as a priority to be protected) by National Highways and other highway authorities.

Impact on irreplaceable habitats

6. Ancient woodland and ancient and veteran trees are considered to be irreplaceable habitats. They provide a plethora of benefits: including carbon storage, a home for wildlife and cultural value. Ancient woodlands cover less than 3% of England’s land area. Over 200,000 ancient, veteran and notable trees are recorded on the Ancient Tree Inventory.

7. The Woodland Trust has evaluated the current portfolio of schemes supported by the Roads Investment Strategies 1 and 2 (Table and chart below). Woodland Trust analysis shows that a quarter (24%) of all schemes have confirmed impacts, as based on publicly available documentation of the schemes, on ancient woodland or veteran trees. A further 20% of schemes are expected to have impact on these irreplaceable habitats based on analysis of the route mapping information. In total 44% of schemes are anticipated to impact ancient woodland and veteran trees, a figure which is replicated for schemes which have already been completed or approved by the Secretary of State.

8. Many of the schemes impact multiple ancient woodlands and ancient and veteran trees. These impacts can be direct, such as via the felling of trees or removal of ancient woodland soils, and indirect, such as through increased noise, light and air pollution or fragmentation as roads sever through landscapes. The Woodland Trust’s assessment finds that:

• 22 ancient woodlands will be directly affected by schemes supported via RIS 1 and 2 (12 confirmed)
• 145 ancient woodlands will be indirectly affected (94 confirmed)
• 82 ancient and veteran trees will be directly affected (all confirmed)
• 83 ancient and veteran trees will be indirectly affected (80 confirmed)

(These figures do not include the schemes that have been withdrawn or where the status of projects is unknown)

9. And so despite covering less than 3% of England’s land area, 44% of schemes were found to impact ancient woodlands. These figures show that change to the strategic road network is failing to take account of direct and indirect impacts on irreplaceable habitats. This is despite existing planning policy that states that “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”[1]. Additionally, many road projects go through the Nationally Significant Infrastructure Project Regime, which also seeks to protect ancient woodland and ancient and veteran trees from proposals.

10. The number and percentage of projects coming forward, and being approved, that harm ancient woodland and ancient and veteran trees is wholly unacceptable.

Table 1: Woodland trust analysis (2023, unpublished) of the impact to ancient woodland and ancient and veteran trees of projects supported via the Roads Investment Strategies 1 and 2.

[1] The impacts are explicitly identified within the publicly available documentation, eg in the Environment Statement; [2] Additional impacts that have been identified by the Woodland Trust based on the route of the proposal.

Figure 1: Woodland trust analysis (2023, unpublished) of the impact to ancient woodland and ancient and veteran trees of projects supported via the Roads Investment Strategies 1 and 2, broken down by stage in the planning process. [1] The impacts are explicitly identified within publicly available documentation, eg in the Environment Statement. Some projects supported via RIS1 had had documentation archived; [2] Additional impacts that have been identified by the Woodland Trust based on the route of the proposal

Legal and policy context:

11. There has been recent progress in our understanding of the value of ancient woodlands and ancient and veteran trees, and improvements to planning protections. These include:

-         The Woodland Trust’s State of UK woods and trees report[2] (published in 2021) has led to improved understanding of the value of ancient woods and veteran trees. This includes the ability of ancient woodlands to store more carbon than younger woodland habitats: England’s ancient woodlands store 36% more carbon than all woodlands.

-         Improved, but not complete, data sets – via updating the Ancient Woodland Inventory[3] – which mean that some work to assess potential impacts can be done via online mapping, in order to avoid harm. However, site surveys still essential to ensure that unmapped ancient and veteran trees, in particular, are identified in the planning process and protected.

-         Government policy, including the refresh of the Keepers of Time policy, reiterates the governments vision to protect, restore and create woods and trees. It reiterates the Government’s position that ancient woodlands and ancient and veteran trees are irreplaceable and should have strong protection.

-         In 2018, the Government’s National Planning Policy Framework strengthened planning protections for ancient woodland and ancient and veteran trees. In 2021, Government committed to improving them further during the progress of the Environment Act through Parliament. While infrastructure specific policy – via the National Policy Statement for National Networks has yet to be updated, it is important that this supports the Government’s commitment to improve protection of these irreplaceable habitats.

12. The Environment Act (2021) recognises that maintaining the status quo on environmental protection is not enough if the twin challenges of the nature and climate crises are to be addressed. The list of Government policy and initiatives that need to be reflected in the next Road Investment Strategy includes:
• The introduction of environmental targets to increase tree canopy cover and halt the decline in nature, as a result of the Environment Act must inform road investment. National Highways are also significantly behind on publishing annual biodiversity reports – this must be brought up to date before embarking on further schemes that could damage nature in a date vacuum.
• The integration of tools such as Biodiversity Net Gain and Local Nature Recovery Strategies are crucial.
• The Government’s own levelling up agenda must also mean levelling up access to nature and be reflected in infrastructure strategy.
• Discussions around a Land Use Framework – a national conversation about how we use the land in the UK for the many priorities and demands it faces, the road investment strategy will need to reflect the outcomes of this.
• The commitment to reach net zero shows the case for rapid and decisive action has not gone away. In his review of the Government’s approach to net zero, Chris Skidmore MP points out that even with the move to electric vehicles, ultimately the aim needs to be on moving away from private vehicle use.  The focus in the meantime should be adopting urgent measures to ensure that car emissions are reduced in line with the Climate Change Committee’s Net Zero pathway, rather than taking actions that risk increasing emissions such as increasing road capacity.
  This is supported by analysis from the Transport Action Network and Transport for Quality of Life. There is a need for clarity and accountability on decarbonisation of the road network and use of application of carbon valuation in appraisal. This was a key part of the recent report of the Roads Investment Scrutiny Panel[4].

13. If the UK Government is going to meet the commitments and targets it has set out for itself, and show leadership in meeting global agreements made at COP15 to protect and improve nature, it must ensure there is join up across all areas of Government – and this includes on road investment.

February 2023

Endnotes