Written evidence submitted by the Woodland Trust [NPP 26]

The Woodland Trust appreciates the opportunity to respond to the Select Committee’s Inquiry. As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.

Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length of time that ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.

Increasing residential density around commuter hubs

In its current form this proposal is very ambiguous and open to abuse. The definitions set out in paragraphs 15a and 15b are very general particularly 15b which defines a frequent service as one running every 15 minutes (or with the potential to run at least every 15 minutes). This is very worrying as there are no measures within the document setting out exclusions or protections for sensitive areas. The Trust’s particular concern lies with the protection of ancient woodland. In it’s current form the proposed changes leave ancient woodland at the mercy of the National Planning Policy Framework (NPPF). The NPPF has already been found to be failing ancient woodland, a fact recognised by your Committee in its 16 December 2014 report into operation of the National Planning Policy Framework (NPPF) which recommended the strengthening of ancient woodland protection through revised wording.

As of December 2015 there are 336 ancient woodlands threatened across England, 259 of these are ‘live’ planning applications  whilst 77 are site allocations. The majority of the site allocations are for housing, illustrating a clear failure in the NPPF preventing such developments coming forward.

In addition the Trust would like to see an emphasis on providing high quality homes and green spaces on these new sites. Further information on this is set out in the next section.

Supporting new settlements

The Trust is acutely aware of the need for new homes across the country and, in particular, affordable homes. We strongly believe that there should be a focus on the quality of the homes and their setting; we should be building communities that people really want to live in, not just focussing the number of units needed across the country.

Paragraph 20 of the consultation document pays lip service to the notion of sustainable development, clearly placing the focus on the supply of new homes. As they stand the proposals are very disappointing and in no way aspirational. They rely on people being desperate for new homes rather than being in a position to choose to live in a place that could provide a much better quality of life and a more resilient environment.

The Trust would like to see public open space and woods and trees at the heart of new developments so that their benefits can be enjoyed by the whole community, both current and future residents. 

Woods and trees have the ability to deliver multiple benefits. Planting schemes should be bespoke to fit the needs of both the site and the community. Woodland creation can do everything from build resilience to flood risk and climate change to helping instil an understanding and respect for the natural environment in children. Evidence proves that the presence of trees can increase house prices as people are willing to pay more for a view of trees.  Indeed since the 1970s studies have found that trees can add between 4% and 7% on to house prices[i]. Their presence can also encourage more active transport choices through walking and cycling, minimising congestion and having a positive impact on residents’ health.

These are just a few of the benefits associated with woods and tree. The Trust is very keen that instead of simply taking this opportunity to boost house building the reforms should promote the building of high quality resilient communities. The Trust has produced a guidance document on this ‘Residential Developments and Trees’ which may be of interest to the Committee:

New research published last year  research has shown the significance of access to beautiful surroundings …..inequality has a significant impact on health and wellbeing as well as the way people behave within communities. Those who are surrounded by beauty are more likely to take care of it, become more involved in their communities. Uglier places see higher levels of anti-social behaviour, crime and more litter. We have to create a system by which we all have a Right to Beauty.[ii]

In addition we would like to draw the Committees attention to the following standards which we believe should be incorporated into all new developments.

Natural England and the Countryside Council for Wales Accessible Natural Greenspace Standard (ANGSt) recommend:

No person should live more than 300m from their nearest area of natural greenspace of at least 2ha in size

o              at least one accessible 20ha site within 2km of home

o              one accessible 100ha site within 5km of home

o              one accessible 500ha site within 10km of home

o              provision of at least 1ha of Local Nature Reserve per 1,000 people

The Woodland Trust’s Woodland Access Standard (developed in association with the Forestry Commission) aspires:

o              That no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size

o              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

New development is an opportunity to embed these aspirations into communities at the earliest possible stage and the reform should take the opportunity to promote them. It its current form there is a risk that the consultation simply promotes building the slums of the future.

Brownfield land in the greenbelt

The greenbelt offers an exciting opportunity for environmental enhancements on the doorstep of vast swathes of the population. The Trust would like to see developments in this unique position close to both town and country recognised and capitalised on to make critical biodiversity links for wildlife as well as providing vital easily accessible greenspace for urban residents. In early discussions about the green belt, such as in an article by David Niven in 1910, emphasis was placed on the green belt being part of a park system with a focus on public access. With increased development occurring in the greenbelt it is critical that the remaining green belt is enhanced and the ecosystems services it provides capitalised upon. In 1914 in a speech to the London Society Aston Webb (architect of the Victoria and Albert Museum) said in his vision of London in 100 years time he saw ‘a beautiful sylvan line practically all around London’ with a certain amount of open spaces, pleasure grounds’. This is an opportunity to fulfil that vision to create communities that are robust and resilient in the face of growing populations and climate change.

There is a concern that with pressure to allocate brownfield land adjoining land uses and habitats will not be properly assessed and the site in question simply considered in isolation. It is critical that in allocating sites the wider landscape scale is considered. The connection between a woodland and other woods or remnants of woods in the area also needs to be understood as connectivity between patches of woodland is important for promoting species diversity within a landscape.

Woodland is a finite resource and ancient woodland cannot be replicated once lost. It is important to understand each individual wood’s importance on a landscape scale as even small losses may have unforeseen impacts on other woods. Pressures from development are varied and are often not obvious, and without a thorough understanding of the ecology of individual woods these pressures are harder to predict and mitigate. For example housing can have significant and quite specific impacts upon ancient woodland:  there are five different effects; chemical (for example run off from salted roads, garden pesticides), disturbance (for example children playing in woodland, predetation by domestic cats), invasion by non-native plant species (for example non native garden plants) as well as fragmentation caused by the development and cumulative effects.

The timing and length of the consultation

The Trust is very grateful to the Committee for the work they did in securing an extension of the consultation period into February as the Christmas and New Year holidays allowed very little time for the submission of a considered response. The Trust is disappointed that the consultation is being run alongside the Housing and Planning Bill putting a massive strain on resources and dividing attention.

January 2016