Regulation 18 draft Local Plan

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Object

Regulation 18 draft Local Plan

Policy EN3 - Biodiversity Net Gain

Representation ID: 4551

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

The LP must go beyond minimum requirements for BNG and be an example of best practice and should:
• Require development projects to deliver 20 per cent BNG
• Give consideration to the quantum of other investment sources (public and private) which will be needed in order to meet these targets.
• Require BNG units to be maintained for a minimum of 50 years, not just the 30 set out in the Environment Act:
- this is particularly important for woodland creation, as it takes many decades for new woods to reach maturity and their full ecological potential.
- deliver a rich mix of habitats including native woodland, informed by LNRSes.
- habitat creation funded through other mechanisms (such as public funds) should also be maintained in the long term.

Support

Regulation 18 draft Local Plan

Policy EN2 - Local Nature Recovery Strategy

Representation ID: 4552

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

The LP should give strong weight to LNRSes for development site allocation at a local level.
• This will be essential to embed avoidance of impacts to existing sensitive natural assets, by providing a ‘spatial’ element to site allocation decisions. It is vital that development is allocated in a way which protects important sites for nature, maintains ecological integrity and maximises potential enhancements from land in recovery.
• Once a site has been allocated in a local plan, it is more likely to receive planning permission, so it is essential to embed ecologically coherent criteria for spatial prioritisation at the framework level.
• LNRSes should also be used to inform priority locations for the provision of green infrastructure, and habitat creation and enhancement through BNG.

Support

Regulation 18 draft Local Plan

Policy EN1 - Protection of Sites, Habitats and Species

Representation ID: 4553

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

Protection of valued habitats must be at the heart of the LP. In particular, irreplaceable habitats, including ancient and veteran trees, must be protected from loss and damage. To achieve this, the LP should:
• Give weight to the relevant LNRS, as it is refined, which should identify ancient woodland sites, to ensure that development is not allocated in close proximity to ancient woodland.
• For veteran trees, the LP should encourage them to be recorded on the Ancient Tree Inventory, and to consider locations where it might be suitable to place a Tree Preservation Order on any ancient, veteran or notable trees recorded. In addition, the LP should encourage a buffer zone to exceed the minimum distances stipulated in planning advice.
• For non-ancient and veteran trees, adopt the Bristol Tree Replacement Standard with respect to felling and specify replacement trees be planted no more than 12 times the distance of the original tree’s trunk diameter, to correspond with root extent area.

Support

Regulation 18 draft Local Plan

Policy EN7: Green and Blue Infrastructure Network

Representation ID: 4554

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

The LP should set standards for high-quality green infrastructure for development.
• Everyone should be able to see three trees from their home.
• Everyone should be no more than 300 metres from the nearest natural green space, with safe and accessible routes.
• Consideration should also be given to the Woodland Trust’s Access to Woodland Standard which aspires that everyone should have a small wood of at least two hectares in size within 500 metres of their home, and a larger wood of at least 20 hectares in size within four kilometres of where they live.

Object

Regulation 18 draft Local Plan

Policy EN4 – Trees, woodland, and hedgerows

Representation ID: 4555

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

Rutland’s tree canopy cover is just nine per cent, which contrasts to around 13 per cent for the UK and an average of 38 per cent across the EU. Therefore, we believe that woodland creation should be a major priority for the LP.

Principally, it is key to select the right tree for the right place and, while we recognise the role non-native trees will play in meeting near-term targets, as well as the ability of some to confront specific concerns like air pollution on busy streets, they should be minimised both to prevent the introduction of pests and diseases through tree importation (viz. biosecurity risk) and to offer the greatest ability for already-existing flora and fauna to benefit.
The maximum possible proportion of new trees should be native, and UK and Ireland Sourced and Grown (UKISG). Not only are some pests hazardous to human health, but supporting local nurseries and tree growers confers an economic benefit.

The overall ambition should be for a canopy cover of 30 per cent in new developments.

Support

Regulation 18 draft Local Plan

Policy EN5- Ancient Woodland and Veteran Trees

Representation ID: 4556

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

There should be a robust commitment to protection for individual ancient and veteran trees where identified.

Support

Regulation 18 draft Local Plan

Chapter 9 – Environment

Representation ID: 4557

Received: 27/11/2023

Respondent: The Woodland Trust

Representation Summary:

Trees and forests are crucial to life on our planet. They stabilise the soil, generate oxygen, store carbon, play host to a spectacular variety of wildlife, and provide us with raw materials and shelter. They offer us respite, inspire our imagination, creativity and culture, and refresh our souls. A world without trees and forests would be barren, impoverished and intolerable.
We are interested in working with Rutland County Council in developing policies beneficial to trees and woodland in its emerging Local Plan (LP). We would also like to work with this authority to enable it to better protect woodland, particularly irreplaceable habitats such as ancient woodland and ancient and veteran trees, and to plant trees as part of a well-planned network of green infrastructure.
It is essential that the climate and nature crises are addressed jointly, with trees’ remarkable ability to fight each recognised by the LP. So, while encouraged by the LP’s references to trees’ biodiversity contribution, and extensive recognition of Biodiversity Net Gain (BNG), we would like it to go further, assigning definite BNG targets while grasping future opportunities afforded by Local Nature Recovery Strategies (LNRSes) required by the Environment Act 2021.
In summary, we consider that the Environmental Principles must be treated as a foundational component of the LP. As part of incorporating the principles, the LP must support the protection of sensitive natural assets, such as ancient and veteran trees; be an exemplar of emerging BNG practice; and set high standards for the retention and provision of trees within developments.

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