We have to object to Policy 3 as written. Whilst it contains some good policy and is obviously well intentioned, we believe that some of the wording is not sufficiently strong on habitat protection and in particular in protection offered to irreplaceable habitats, such as ancient woodland and ancient/veteran trees. We would like to see protection given to these habitats which is at least as strong as the protection given in Para 175c of the NPPF, where it states that any development having adverse impacts on ancient woodland and/or veteran trees will be wholly exceptional.

We have made a separate submission on your site allocations, as we believe that allocation GNLP0132 will adversely impact an area of ancient woodland. We have submitted a letter with our objection, which goes into much more detail on this point. It is possible that lack of strength in the wording of policy 3 is one of the factors which allows such site allocations to be put forward.

We would also like to echo the words of the local parish council which has commented on Policy 3 to the effect that their is a lack of specific reference to woodland creation or tree planting and that this is a significant omission, given current concern over the climate emergency. The Woodland Trust has recently published an Emergency Tree Plan in which we are urging that both protection of existing trees and ambitious targets for planting new trees and woods must have an important role in any local climate action plan. In its recent election manifesto, the current Government made a commitment to creating 30,000 hectares of new woodland each year, which is equivalent to 30 million trees per year and the importance of tree planting was also stressed in DEFRA's 25 Year Environment Plan.

There are some references in the supporting text to creation of some new country parks and these may well include some trees and woods but there is no explicit requirement for this in the policy.

The precise form of any planting target is a matter for debate but in the Emergency Tree Plan we have suggested that areas of new development should include 30% tree canopy cover. Your local plan could include an aim of measuring canopy cover (through one of the recognised techniques such as ITree) and an ambitious target for enhancing it, both on council owned land and on private land.

An alternative strategy adopted by some councils is set an ambitious target in terms of number of trees to be planted (eg one for every person in the area covered by the plan over 5 years, which would be in line with the target recently announced by Norfolk County Council.

Alternatively, you could use the Woodland Trust's Access to Woodland Standard, which aspires that everyone should have a wood of at least 2ha in size within 500 metres of their home and a larger wood of at least 20ha within 4km. Our report Space for People, available on our website, shows the percentage woodland access achieved by each council. For Norwich City it is 16.9% for the first part of the standard and 78.4% for the second part. We are happy to supply this information for the other councils in the joint planning unit, if that would be of assistance, and in your local plan you might want to set targets for % woodland access to be enhanced.