Draft Greater Norwich Local Plan – Part 1 The Strategy

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.

We do not feel that the wording of this policy is strong enough in the light of the ongoing climate emergency. This comment is true of a number of aspects of the climate change policy including references to promotion of sustainable transport and to encouraging renewable energy but I would like to specifically focus on the role of green infrastructure and in particular of trees and woods.

It is stated that development must include green infrastructure but there is no mention of the specific ability that trees and woods have to sequester carbon from the atmosphere, which is much greater thatn, for example, areas of intensively mown grass. There is a further advantage that woods can be considerably cheaper to manage than intensively mown grass, as evidenced by research which is outlined in the Woodland Trust's Trees or Turf report, which is available from the publications section of our website.

Trees can also help in adaptation to the impact of climate change, for example by significantly reducing midsummer temperatures in urban areas. This could be referred to in the policy.

There is a reference to the need to reduce surface water flooding but again no reference to the specific role that trees can play in this, particularly in urban areas. Research by the University of Manchester has shown that run off of water into drainage systems can be reduced by up to 60% by presence of trees: trees achieve this through their foliage reducing the rate at which rainwater reaches the ground.