Memorandum submitted by the Woodland Trust
1. The Woodland Trust welcomes the opportunity
to respond to this consultation. The Trust is the UK's leading
woodland conservation charity. We have four main aims: no further
loss of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
SUMMARY
— House building will have a significant
impact on the success of both climate change mitigation and adaptation
strategies. Ensuring that the natural environment and society
can adapt to the negative impacts of climate change is essential,
and this is now recognised by some leading politicians including
the EU Commissioner for the Environment, Stavros Dimas, who argued
that "loss of biodiversity is a threat to the planet that
is equally important as climate change".1
— Constructing three million new homes
could have a huge environmental impact if they fail to take cognisance
of the natural environment.
— Eco-towns must avoid damaging semi-natural
habitats if they are to be considered as a genuine example of
sustainable development. Importantly the natural environment must
not be an afterthought in the planning process, and new developments
should protect all semi-natural habitat.
— The eco-town initiative could afford
a real opportunity to imbed high quality green infrastructure
within new developments by providing public access to biodiverse
green space where it is currently lacking.
Reducing carbon emissions from new homes
2. Whilst the Trust welcomes the commitment
to making all new homes zero carbon by 2016, it should be remembered
that eco-towns represent less than 10% of the three million new
homes the Government seeks to build by 2020. It is therefore crucial
that the other 90% of housing is built to the highest of standards
and that old stock is retrofitted to make it energy efficient.
3. The UK is dependent on a healthy natural
environment for "services" such as flood alleviation,
air purification and enhanced soil quality, and if people are
to continue benefit from these more emphasis must be given in
the planning process to protecting, expanding and restoring natural
resources.
4. Development should therefore not be sited
in environmentally important areas, regardless of its propensity
to deliver carbon-lean infrastructure. High quality biodiverse
green space should be a key feature of new development, both in
order to enhance the quality of life of residents and as part
of climate change adaptation strategies.
5. Legal and sustainably sourced wood can
make a significant contribution to reducing the carbon emissions
of new development by forming part of a strategy that will substitute
high carbon materials like cement and steel for low carbon alternatives.
Product substitution is increasingly viewed as a valuable contribution
to mitigating climate change, and the Trust would like this demonstrated
when the Government builds new homes and eco-towns.
Eco-towns
6. The Trust believes that if eco-towns
are to genuinely showcase environmentally sustainable living they
must protect, buffer and extend semi-natural habitat. They should
not be manipulated to recycle failed bids, and neither should
their creation justify removing precious habitat. If bids are
likely to denigrate semi-natural habitat and surrounding green
space on which the public are reliant they should be rejected.
7. Another often forgotten consideration
are the negative edge effects from adjoining land-use and the
commensurate damage this can have on environmentally sensitive
areas. A habitat does not have to be physically removed to be
degraded by development. To prevent this less obvious type of
damage, the Trust asks that all ancient and long-established woodland
be buffered from diffuse pollution and infrastructure development
that may emanate from the nascent eco-towns.
8. Government policy understandably seeks
to re-develop brownfield sites, however some of these hold an
array of biodiversity found on the UK Biodiversity Action Plan
(BAP). The potential to lose these species, at a time when EU
targets place a premium on their preservation, makes it imperative
for the planning process to safeguard both biodiversity and the
habitats upon which it is dependent.
9. A report by the Sustainable Development
Commission Health, place and nature,2 demonstrated that
accessible green space provides discernible health benefits by
improving life expectancy and alleviating mental illness. If they
are to illuminate sustainable living and improve the quality of
life to their residents, all proposed eco-towns must deliver access
to green spaces. One indicator which has been developed by the
Woodland Trust, based upon surveys of green space use and existing
standards, is a woodland access standard that aspires to see that
no person should live more than 500 metres from at least one area
of accessible woodland of no less than 2 hectares in size. It
also aspires that there should be at least one area of accessible
woodland of no less than 20 hectares within 4km of people's homes.3
10. The Trust believes that eco-towns should
be exemplars in green infrastructure, and the proposals must be
judged on whether they stay within environmental limits, offer
opportunities for wildlife to adapt by connecting landscapes,
and imbue a sense of community engagement and ownership.
Greenfield and green belt developments
11. Finally, Planning Policy Statement 9,
Biodiversity and Geological Conservation4 and the supplement to
PPS 1, Planning and Climate Change5 recognised the importance
of protecting biodiversity. PPS 9 gave assurance that "The
aim of planning decisions should be to prevent harm to biodiversity
and geological conservation interests".6 It also gave specific
mention to the crucial role of ancient woodland as "a valuable
biodiversity resource both for its diversity of species and its
longevity as woodland once lost cannot be recreated".7 The
Trust believes that these previously agreed controls should be
exercised to oppose development where it may impact negatively
on the environment, irrespective of whether the land is classified
as "greenfield", "greenbelt", or "brownfield".
REFERENCES
1 Commissioner Stavros Dimas, Natura 2000
as an opportunity or obstacle to development, Commission Speech
(16 April 2008).
2 The Sustainable Development Commission, Health,
place and nature How outdoor environments influence health and
well being: a knowledge base (2008), at http://www.sd-commission.org.uk/publications/downloads/Outdoor_environments_and_health.pdf
3 The Woodland Trust, Space for People: Targeting
action for Woodland Creation (2004), at http://www.woodland-trust.org.uk/publications/publicationsmore/spaceforpeople.pdf
4 Department for Communities and Local Government,
Planning Policy Statement 9: Biodiversity and Geological Conservation
(August 2005), at http://www.communities.gov.uk/publications/planningandbuilding/pps9
5 Department for Communities and Local Government,
Planning and Climate Change—Supplement to Planning Policy
Statement 1 (December 2007), at http://www.communities.gov.uk/publications/planningandbuilding/ppsclimatechange
6 Department for Communities and Local Government,
Planning Policy Statement 9, p. 3.
7 Ibid, p. 6.
25 April 2008
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