Memorandum from the Woodland Trust
The Woodland Trust welcomes the opportunity to respond
to this consultation. The Trust is the UK's leading woodland conservation
charity. We have three aims: to enable the creation of more native
woods and places rich in trees; to protect native woods, trees
and their wildlife for the future; to inspire everyone to enjoy
and value woods and trees. We own over 1,000 sites and have 300,000
members and supporters.
SUMMARY
- Coalition Government plans to incentivise local
communities to accept new housing development should reflect appropriate
mechanisms to ensure that the planning process still provides
protection for irreplaceable natural habitats like ancient woodland,
and also to support new native woodland creation in order to contribute
to a net increase in trees and woods in local areas.
- Local community housebuilding incentives should
be coupled with similar local incentives to improve peoples' quality
of life, such as creating new native woods. Environmental improvements
should be planned and coordinated at a "landscape scale".
- The positive benefits of sub national level environmental
planning and delivery should be carried forward into the new localism
model.
- The Local Enterprise Partnerships should not
be given any planning powers once held by regional and local government
as it risks undermining the notion of a planning system that is
democratically accountable and able to integrate environmental,
social and economic concerns.
- Sub national data and information on the natural
environment should be "banked" and made available to
local authorities to aid continuance of "landscape scale"
environmental planning and delivery.
The implications of the abolition of regional
house building targets for levels of housing development
N/a.
The likely effectiveness of the Government's plan
to incentivise local communities to accept new housing development,
and the nature and level of the incentives which will need to
be put in place to ensure an adequate long-term supply of housing
1. Whilst we support in principle the wider thrust
of the Government's new localism drive as a key plank of the "Big
Society" approach, the Woodland Trust has concerns in respect
of house building incentive proposals such as The Community
Right to Build,1 which risk bypassing the professional
integrity of the planning process and thus resulting in inappropriate
development. We would prefer to see enhanced engagement
of local communities through the existing local development plan
process, scrutinised transparently by democratically elected councillors,
rather than an advocacy model potentially open to manipulation
by powerful single issue pressure groups rather than genuine local
opinion.
2. For instance, local opinion may inevitably
not be fully aware of the wider implications for adjacent ancient
woodland, a complex and irreplaceable semi-natural habitat constantly
under direct and indirect threat from inappropriate land use.2
Between 1930 and the production of the ancient woodland inventories
in the 1980s, 7% of the remaining ancient woodland in England
and Wales was permanently cleared and 38% converted to plantation.3
Ancient woodland has yet to benefit from full statutory protection:
for example 85% of ancient woodland in the UK still has no legal
designation.4 This is particularly relevant as ancient
woodland, especially the large amount contained in small fragmented
pockets, is still facing considerable threats from development
and the effects of climate change. Some protection for ancient
woodland is, however, provided by Planning Policy Statement 95
which states:
"Ancient woodland is a valuable biodiversity
resource both for the diversity of species and for its longevity
as woodland. Once lost it cannot be recreated. Local planning
authorities should identify any areas of ancient woodland in their
areas that do not have statutory protection (eg as an SSSI). They
should not grant planning permission for any developments that
would result in its loss or deterioration….".
It is important that the new local incentive mechanisms
continue to be consistent with such national planning policy guidance.
The Committee understands that the Government
intends to announce further details of its plans for incentives
"shortly", and would welcome comments on the adequacy
and appropriateness of those incentives when the details are available
3. The Woodland Trust is concerned that local
community house building incentives should be coupled with equivalent
local incentives for other key policy priorities relating to land
use development for placemaking and peoples' quality of life.
Incentives should reward broader stewardship of the public realm,
environment and natural resources rather than simply housing quantity.
It is important that the new emphasis on localism does not lose
the wider policy and delivery perspective available at a sub national
level. For instance the Trust believes that creating new native
woods and planting trees is not a luxury. Instead tree planting
is an essential action in developing green infrastructure that
can deliver a wide range of benefits by mitigating and adapting
to the effects of climate change, reducing flood risk and improving
water quality, aiding productive agriculture, halting wildlife
loss, enhancing public health and shaping places where people
want to live, work and spend their leisure time. This is supported
by Government policy—the National Tree Planting Campaign6
and the Low Carbon Transition Plan.7
4. Woodland creation can also bring a range of
other direct benefits. The Mersey Forest project showed that for
every £1 invested in woods and trees there was a return of
£10.8 The Trust's policy briefing
Greening the Concrete Jungle illuminates the compelling
economic rationale for expanding the UK's native wood and tree
cover.9 For example trees and woods could save millions
in healthcare costs. Around £110 billion is spent each year
in the UK on healthcare, equal to 8.5% of all income. It has been
estimated that if every household in England had good access to
quality green spaces such as woodland it could save around £2.1
billion annually.10 Trees and woods therefore offer
genuine value for money at a time of enormous pressure on the
public finances. Moreover, assuming that the new Local Enterprise
Partnerships are going to be empowered to deliver long term prosperity
and regeneration, they need to have an appreciation of the important
place of environmental and social concerns in the wider regeneration
agenda, alongside their more obvious role in securing economic
growth.
5. Delivery of this much needed woodland creation
is increasingly planned at a landscape scale that often transcends
local district or neighbourhood boundaries, following instead
natural landscape, geological and biodiversity delineations. Government
policy has responded to this: Many of the ecosystem services
we seek from trees, woods and forests in the future will require
us to look outwards from individual woodland sites and think about
the impact they will have on surrounding land uses and resources
(and the effect of these on the woodland too). This is called,
for want of a better term, the "landscape-scale" approach,
but it is not just about visual impact, it is about groundwater
and flood management, shelter, air pollution, soil conservation,
adaptation of woodland ecosystems, and providing green spaces
in and around built-up areas.11
6. It is therefore important that woodland creation
policy and delivery continues to be planned at a landscape scale,
and we have concerns about the practicality of this in terms of
a local incentive model without guidance from some sort of a sub
national planning or governance structure.
The arrangements which should be put in place
to ensure appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies (eg.
waste, minerals, flooding, the natural environment, renewable
energy, &c)
7. The Woodland Trust believes that the natural
environment (for instance landscape and biodiversity or green
infrastructure) benefits from planning and delivery at a sub national
or "landscape" scale. We would therefore like to see
the positive benefits of this sub national approach carried forward
in the change of emphasis to local level planning through local
authority cooperation.
8. A good example of emerging best practice
with regard to environmental planning at a sub national level
is illustrated by the work previously undertaken for the now aborted
West Midlands Spatial Strategy Phase Three Revision to 2026.
This has been archived as Interim Policy Statements and Policy
Recommendations.12 The Integrated Approach
to Management of Environmental Resources section of the document
makes this point, and references its relationship to green infrastructure
planning: The WMRSS aims to reflect the interrelationships
between environmental assets by ensuring that all assets are conserved
and enhanced together, rather than individually. This approach
responds to the new emphasis on ecosystems, landscape scale planning,
place making and green infrastructure planning. The Update
of Policy Q8—Trees, Woods and Forestry similarly proposes:
Seek to take forward the major contributions trees and woodlands
can provide for delivery of related work on identifying regional
natural environment priorities and other initiatives, including
ecosystem services delivery at a landscape scale. This best
practice is being successfully delivered on the ground at a sub
national level through initiatives such as the West Midlands Biodiversity
Partnership's Landscapes for Living opportunity mapping
project13 and the Forestry Commission's Woodland Opportunity
Mapping initative.14
The adequacy of proposals already put forward
by the Government, including a proposed duty to co-operate and
the suggestion that Local Enterprise Partnerships may fulfil a
planning function
9. The Woodland Trust is pleased to see the proposed
duty to cooperate but—as highlighted above—we have
concerns that sub regional liaison may lose the wider "landscape
scale" planning perspective that the natural environment
needs to maximise delivery of its economic and social benefits.
10. The Trust is very concerned at the press
coverage from the seminar between business leaders and Local Authorities
where it is suggested that the LEPs may assume planning functions.15
We believe that this would contradict the spirit and detail of
the Coalition agreement which aimed to herald an era of localism
by returning planning powers to Local Authorities. Indeed, the
letter of the 29 June 2010 from the Secretaries of State for Business
Innovation and Skills, Vince Cable, and Communities and Local
Government, Eric Pickles, failed to mention any transfer of planning
powers to the LEPs.16 The Trust believes that it would
be inappropriate to give LEPs planning powers as they have neither
the democratic legitimacy nor the skills set needed to integrate
environmental, social and economic objectives.
11. We also have concerns about the ability of
LEPs to engage with—and provide funding for—the environmental
agenda given their likely focus on economic growth. Understandably
LEPs will come under pressure to secure private sector growth
and as such are expected to be led by prominent members of the
business community. However, if these bodies are destined to enact
decisions that affect social and environmental aspirations they
should incorporate expertise from these sectors. Without this
type of inclusive partnership there is a risk of marginalising
the environmental agenda at a time when there is widespread recognition
that the environment and prosperity are not in competition but
intertwined and the Coalition government rightly aspires to be
the "greenest government ever". In the foreword to the
consultation on the Natural Environment White Paper, the Defra
Secretary Caroline Spelman, rightly points out that "our
natural environment has a broader national value. It underpins
our economic prosperity, our food security, our health, our ability
to adapt to a changing climate and to reduce the greenhouse gases
which cause this change", and highlights that "degradation
of our planet's ecosystems is costing us €50 billion each
year—a figure that could rise to the equivalent of 7% of
global GDP by 2050".17 A healthy natural environment
is crucial to our continued economic prosperity and should not
be considered an optional luxury. It should therefore be a key
element of the LEP's remit.
How the data and research collated by the now-abolished
Regional Local Authority Leaders' Boards should be made available
to local authorities, and what arrangements should be put in place
to ensure effective updating of that research and collection of
further research on matters crossing local authority boundaries
12. Many regions through their regional assemblies
and/or leaders boards have developed extensive libraries of evidence
on environmental and indeed other key issues and it is important
that all sub national data and information is retained as a resource
for future policy development, whether at the local or sub regional
level. Similarly the Regional Development Agencies will also have
accumulated substantial evidence banks to inform the environmental
proofing of their Regional Economic Strategies. For instance the
Interim Policy Statements and Policy Recommendations archived
as part of the now aborted West Midlands Spatial Strategy Phase
Three Revision to 2026 are underpinned by detailed background
papers on key environmental topics including an Integrated Approach
to Management of Environmental Resources, Green Infrastructure,
Conservation, Enhancement & Restoration of the Region's Landscape,
Protecting, Managing & Enhancing Region's Biodiversity and
Geodiversity and Trees, Woods and Forestry.18 It is
important that this sub national environmental information and
data is archived in a "library" that is easily accessible
to all local authorities, with arrangements for updating over
time.
REFERENCES
1 http://www.communities.gov.uk/publications/housing/righttobuildleaflet.
2 Defra/Forestry
Commission, Keepers of Time—A Statement of Policy for
England's Ancient & Native Woodland (2005), P12-13.
3 Spencer and
Kirby (1992), An inventory of ancient woodland in England and
Wales, Biological Conservation 62 (p77-93).
4 Woodland Trust—http://www.woodlandtrust.org.uk/en/why-woods-matter/protection/ancient-woods/Pages/ancient-woods.aspx.
5 Office of the
Deputy Prime Minister, Planning Policy Statement 9: Biodiversity
and Geological Conservation (August 2005), p6.
6 HM Government,
The Coalition—our programme for government, (May
2010), p17.
7 HM Government,
The UK Low Carbon Transition Plan—National strategy for
climate change and energy, (July 2009), p160.
8 The Mersey Forest,
The Economic Contribution of the Mersey Forest's Objective
One-Funded Investments (October 2009).
9 Woodland Trust,
Greening the Concrete Jungle (June 2010).
10 Defra, An
invitation to shape the Nature of England (July 2010), p1.
See the transcript from the speech of the Rt Hon. Caroline Spelman
where she offers a figure for the health savings that accrue from
a health natural environment: http://ww2.defra.gov.uk/2010/07/27/caroline-spelman-speech-white-paper/
11 Defra, A
Strategy for England's Trees, Woods and Forests, (June 2007),
p24.
12 West Midlands
Regional Assembly, West Midlands Regional Spatial Strategy
Phase Three Revision—Interim Policy Statements and Policy
Recommendations, (March 2010), p51 & 65,
(http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/RSS_Revision/RSS_Revision_Phase_3.aspx).
13 http://www.wmbp.org/landscapes_for_living/opportunity_mapping
14 http://www.growingourfuture.org/wmwff/taskgroups/wom.htm
15 Department
for Business, Innovation and Skills, Business Leaders
and Local Authorities gather to discuss Local Enterprise Partnerships
(Departmental Press Release, 28 July 2010).
16 Letter from
the RT Hon Dr Vince Cable MP Secretary of State for Business,
Innovation and Skills and President of the Board of Trade and
the RT Hon Eric Pickles MP Secretary of State for Communities
and Local Government to Local Authority Leaders and Business Leaders
(29 June 2010).
17 Defra, An
invitation to shape the Nature of England, p2.
18 See note 12
above.
September 2010
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