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Policy PO13: Inclusive, Safe & Healthy Communities

Object
We are pleased to see the commitment in the fourth bullet point of Policy PO13 to protecting and improving the quality of existing open spaces. However we would like to see this policy support creation of accessible green space, such as native woodland, for quality of life benefits. This is strongly supported in the Warwick District GI Delivery Assessment February (LUC, 2012).

The Government's new National Planning Policy Framework (NPPF) states that: 'Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up‑to‑date assessments of the needs for open space, sports and recreation facilities an opportunities for new provision (DCLG, March 2012, para 73).

The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, paras 4.5-4.13) highlights the direction of national policy regarding the natural environment and health: 'Nature is good for human health. There is a wealth of evidence on the positive effect that spending time in the natural environment has on the health and emotional wellbeing of children'.

The Case for Trees: Forestry Commission (2010) sets out: 'The multiple value of trees for people and places - increasing greenspace and tree numbers is likely to remain one of the most effective tools for making urban areas more convivial', and lists those benefits (on p.10) as -
- Climate change contributions
- Environment advantages
- Economic dividends
- Social benefits.

The Woodland Trust believes that proximity and access to woodland is a key issue linking the environment with health and wellbeing provision.

Recognising this, the Woodland Trust has researched and developed the Woodland Access Standard (WASt) for local authorities to aim for, encapsulated in our Space for People publication. We believe that the WASt can be an important policy tool complimenting other access standards used in delivering green infrastructure for health benefits.

The WASt is complimentary to Natural England's ANGST+ and is endorsed by Natural England. The Woodland Trust Woodland Access Standard recommends:
- 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.
Applying this standard in Warwick District, with a comparison against North Warwickshire DC Council and the West Midlands as a whole, gives the following figures (see table below). It shows that Warwick exhibits below average access in the smaller wood category. This presents an excellent opportunity for creating more accessible woodland to improve health & well being opportunities for sustainable communities and neighbourhoods. The data used can be supplied free of charge by the Woodland Trust both in map and in numerical/GIS form.
Accessibility to Woodland in Warwick using the Woodland Trust Woodland Access Standard
Warwick DC North Warwickshire DC All WM
Accessible woods % population with access to 2ha+ wood within 500m 12.5% 17.0% 15.4%
% population with access to 20ha+ wood within 4km 85.4% 92.3% 63.8%

Space for People' is the first UK-wide assessment of any form of greenspace - the full 'Space for People' report can be found at http://www.woodlandtrust.org.uk/en/about-us/publications/key-publications/space-for-people/Pages/space-for-people.aspx.

In addition, our VisitWoods initiative is an online woodland database of the UK's woods where you are welcome to visit, currently listing over 10,000 sites - http://visitwoods.org.uk/en/visit-woods/about/pages/more-information.aspx.

As an example of other Local Authority policies, the North Somerset Council Core Strategy Adopted April 2012 states -

'CS9: Green infrastructure
The existing network of green infrastructure will be safeguarded, improved and
enhanced by further provision, linking in to existing provision where appropriate,
ensuring it is a multi-functional, accessible network which promotes healthy lifestyles,
maintains and improves biodiversity and landscape character and contributes to climate
change objectives.
Priority will be given to:
.........
* the protection and planting of trees in woodlands and urban areas, particularly native
trees, for public amenity and climate change mitigation and benefits to biodiversity,
health and recreation'.


Proposal
We would therefore like to see the 4th bullet point of Policy PO13 amended (upper case) to read: 'protect and improve the quality of existing open spaces in the District AND EXPAND open space provision SUCH AS NATIVE WOODLAND as the towns
and villages grow over the plan period'.


Policy PO15: Green Infrastructure

Object
Whilst we note that Policy PO15 states that 'Development will only be permitted which protects and enhances important green infrastructure assets and positively contributes to the character and quality of its natural and historic environment through good
habitat/landscape design and management', we believe this policy is insufficiently robust to protect irreplaceable semi natural habitats like ancient woodland.

Ancient woodland, together with ancient/veteran trees, represents an irreplaceable semi natural habitat that still does not benefit from full statutory protection: for instance 84% of ancient woodland in the West Midlands has no statutory protection. This is particularly relevant as ancient woodland is still facing considerable threats - research from the Woodland Trust shows that in the last decade 100 square miles (26,000 hectares or 5% of the total amount of ancient woodland remaining in the UK) of ancient woodland in the UK has come under threat from destruction or degradation. Development threats associated with transport and infrastructure appeared to be the most significant (31% of cases), followed by amenity and leisure developments (14%), housing (10%), and quarrying and mineral extraction (6%). As Warwick DC's ancient woodland amounts to 2.64% as a proportion of its land area, compared to a national average of 2.4%, it is critical that no more of this valuable resource in Warwick is lost.

Warwick District also contains a number of ancient and veteran trees, and there may be more that are not yet formally recorded. The Woodland Trust and Ancient Tree Forum are running a national project - the Ancient Tree Hunt - to identify and map ancient trees (http://www.ancienttreehunt.org.uk/) so they can be protected and enhanced for the benefit of all. As a result a number of ancient trees have been identified, such as the ancient oak at Old Milverton.

Government policy is increasingly supportive of absolute protection of ancient woodland and ancient trees. The new National Policy Planning Framework clearly states: "...planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss " (DCLG, March 2012, para 118).

This NPPF wording should be considered in conjunction with other national policy on ancient woodland -

- The Government's policy document 'Keepers of Time - A statement of Policy for England's Ancient & Native Woodland' (Defra/Forestry Commission, 2005, p.10) states: 'The existing area of ancient woodland should be maintained and there should be a net increase in the area of native woodland'.
- The Government's just published Independent Panel on Forestry states: 'Government should reconfirm the policy approach set out in the Open Habitats Policy and Ancient Woodland Policy (Keepers of Time - A statement of policy for England's ancient and native woodland).....Reflect the value of ancient woodlands, trees of special interest, for example veteran trees, and other priority habitats in Local Plans, and refuse planning permission for developments that would have an adverse impact on them.' (Defra, Final Report, July 2012).
- The Government's Natural Environment White Paper - The Natural Choice: securing the value of nature (HM Government, July 2011, para 2.56) states that: 'The Government is committed to providing appropriate protection to ancient woodlands....'.
- The new Biodiversity Strategy for England (Biodiversity 2020: A Strategy for England's Wildlife & Ecosystem Services, Defra 2011, see 'Forestry' para 2.16) states that - 'We are committed to providing appropriate protection to ancient woodlands and to more restoration of plantations on ancient woodland site'.
- The West Midlands Forestry Framework (Growing our future, May 2010, Forestry Commission) Objective EB2 seeks: 'To prevent any further loss of ancient woodland and to enhance ancient semi-natural woodland and trees with new native woodland planting...'

In terms of compensatory measures, it is impossible to replace ancient woodland as this habitat has evolved over centuries and it is impossible to replicate hundreds of years of ecological evolution by planting a new site or attempting to translocate it.

An example of good Local Authority policy is provided by North Somerset Council Core Strategy Adopted April 2012 -

'Policy CS4: Nature conservation
North Somerset contains outstanding wildlife habitats and species. These include limestone grasslands, traditional orchards, wetlands, rhynes, commons, hedgerows, ancient woodlands and the Severn Estuary. Key species include rare horseshoe bats, otters, wildfowl and wading birds, slow-worms and water voles.
The biodiversity of North Somerset will be maintained and enhanced by:...
3) seeking to protect, connect and enhance important habitats, particularly designated
sites, ancient woodlands and veteran trees'.

The West Dorset DC and Weymouth/Portland DC Local Plan (submission draft: June 2012) states that -

'Policy ENV 2. WILDLIFE AND HABITATS
iv) Elsewhere, development that would adversely affect nature conservation interests,
including Sites of Nature Conservation Importance, Local Nature Reserves, ancient
woodlands, veteran trees and hedgerows, and key wildlife corridors will be
resisted'.

Proposal
We would therefore like to see Policy PO15 amended to reflect the precise wording of NPPF para 118 with a new separate bullet point specifically for ancient woodland: 'The Council will not permit any development proposal which would result in the loss or deterioration of ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss'.


Policy PO15: Green Infrastructure

Object
We would also like to see the 'Development Proposals' section of Policy PO15 reflect the strong message in the Warwick District Green Infrastructure Delivery Assessment (LUC, Feb 2012) and support the expansion of native woodland and tree planting in development situations, particularly in an urban setting.

The National Planning Policy Framework (NPPF) supports the need for more native woodland creation by stating that: 'Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (DCLG, March 2012, para 114). Also para 117 states that: 'To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan'.

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim - 'Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England', (Biodiversity 2020: A strategy for England's wildlife and ecosystems services, DEFRA 2011, p.26).

A reading of these new policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that native woodland creation should form a high priority for this Core Strategy.

As the UK is one of the least wooded areas of Europe, with just 11.8% woodland cover compared to around 44% for Europe as a whole, the Woodland Trust is therefore working to achieve its ambitious aim of doubling native woodland cover over the next 50 years. The Woodland Trust believes that woodland creation is especially important because of the unique ability of woodland to deliver across a wide range of benefits - see our publication Woodland Creation - why it matters (http://www.woodlandtrust.org.uk/en/about-us/publications/Pages/ours.aspx). These include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets).

Woodland creation also forms a significant element in the conclusions of the Government's just published Independent Panel on Forestry, which states: 'Ensure woodland creation, tree planting and maintenance is part of the green space plan for new commercial and housing development' (Defra, Final Report, July 2012). It also recommends: 'Government to commit to an ambition to sustainably
increase England's woodland cover from 10% to 15% by 2060, working
with other landowners to create a more wooded landscape'.

A good example of Local Authority policy is afforded by the North Somerset Council Core Strategy Adopted April 2012 -

'Policy CS4: Nature conservation
The biodiversity of North Somerset will be maintained and enhanced by:...
5) promoting native tree planting and well targeted woodland creation, and
encouraging retention of trees, with a view to enhancing biodiversity'.

Proposal
We would therefore like to see the second bullet point under Development Proposals in Policy PO15 amended (upper case) to read: 'Development proposals should take a positive, integrated approach to designing green infrastructure on site, particularly urban extensions, utilising the Council's preferred approach to new sustainable garden
suburbs with enhancements to key landscape features INCLUDING NATIVE WOODLAND CREATION and the wider GI network.