Draft Nottinghamshire Minerals Local Plan

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Comment

Draft Nottinghamshire Minerals Local Plan

Question 25: What do you think of the draft policy wording for DM4: Protection and enhancement of biodiversity and geodiversity

Representation ID: 32146

Received: 28/09/2018

Respondent: Woodland Trust

Representation Summary:

The 2018 revision significantly improves the protection of ancient woodland with the revised policy set out in
paragraph 175c.
This is a significant change from the wording set out in Policy DM4: Protection and Enhancement of
Biodiversity and Geodiversity which echoes the 2012 NPPF. We hope to see this updated in the next iteration of your plan.

It must be noted that the PPG gives equal protection to Plantations on Ancient Woodland Sites (PAWS) as it does to Ancient Semi-Natural Woodland (ASNW). We are also expecting the PPG to be further updated to reflect the NPP revisions.

Full text:

Nottinghamshire County Council Draft Minerals Local Plan Consultation
As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved.
We own and manage over 1000 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.
Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide
for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost.
As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.
Approximately one quarter of priority UK BAP species are associated with woodland habitats.
Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.
Planning Policy
We note that you recognise that your consultation period overlaps with the publication of the revised NPPF and that subsequent drafts will reflect the new framework. The 2018 revision significantly improves the protection of ancient woodland with the revised policy set out in paragraph 175c:
...development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional
reasons58 and a suitable compensation strategy exists; and
Footnote 58 states:
For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat.
This is a significant change from the wording set out in Policy DM4: Protection and Enhancement of Biodiversity and Geodiversity which echoes the 2012 NPPF. We hope to see this updated in the next iteration of your plan as per your commitment set out on page nine of the draft.

It must be noted that the Planning Practice Guidance (PPG) gives equal protection to Plantations on Ancient Woodland Sites (PAWS) as it does to Ancient Semi-Natural Woodland (ASNW) (Paragraph:
021 Reference ID: 8-021-20140306). We are also expecting the PPG to be further updated to reflect the NPP revisions.
Allocated Sites
Planning authorities and inspectors increasingly act to prevent its direct destruction. However, the damage and impacts posed to ancient woods by nearby development are not so widely appreciated.
As such we are concerned to see that minerals activities have been allocated next to two ancient woodland sites, as set out in the table below. We request that every effort is made to appropriately buffer these woodlands with new planting of a minimum of 50m to protect their unique and irreplaceable nature. Please consult the Woodland Trust at the earliest opportunity in the event of any future applications on the site.
Site Allocation Nottinghamshire County Council's Draft Minerals Local Plan 2018

MP2r - Botany Bay
Retford Sand and gravel quarry
Adjacent Unmapped ancient woodland
Barnby Fox Covert*
(SK6676383259)
MP2s - Mill Hill (Near Barton in Fabis) Beeston Sand and gravel quarry
Adjacent Brandshill Wood -
ASNW**
(SK5307433430)
*Ancient woodland status of Barnby Fox Covert should be assessed by Natural England.
**Currently being added to the Ancient Woodland Inventory by Natural England.

Intensifying land uses adjacent to ancient woodland can have a significant impact upon the woodland in a number of different ways:
Increased activity such as through mineral extraction can result in: modified local hydrological regimes; vibration; noise and light pollution; vehicular collisions with wildlife; external activity visible from within the wood; an increase in wind-blown litter accumulation; and tree surgery or felling along the woodland edge for safety reasons or subsidence prevention.
Noise and light pollution interfere with interactions between species, affecting foraging and predation, reducing breeding success and thereby affecting on-going population viability.
Disturbance may, therefore, lead to species being eliminated from woods.
Vegetation clearance near to ancient woodland may affect woodland hydrology, increasing the likelihood of water-logging or drought and leading to loss of trees and changes in species composition. Soil compaction adjacent to woodland increases water run-off and soil erosion. It can cause severe damage to tree roots, leading to tree defoliation, crown dieback, and death.
The Trust asks that ancient woodland is considered as a key constraint in the future development of these sites and that the appropriate planted buffer is put in place. We would also take this opportunity to ask to be consulted on all forthcoming applications affecting ancient woodland.

Comment

Draft Nottinghamshire Minerals Local Plan

Question 11: What do you think of the draft site specific sand and gravel allocations?

Representation ID: 32147

Received: 28/09/2018

Respondent: Woodland Trust

Representation Summary:

Ancient woodland is located close to the two following draft allocations:
MP2r - Botany Bay
Retford Sand and gravel quarry
Adjacent Unmapped ancient woodland
Barnby Fox Covert*
(SK6676383259)
MP2s - Mill Hill (Near Barton in Fabis) Beeston Sand and gravel quarry
Adjacent Brandshill Wood -
ASNW**
(SK5307433430)
*Ancient woodland status of Barnby Fox Covert should be assessed by Natural England.
**Currently being added to the Ancient Woodland Inventory by Natural England.

Full text:

Nottinghamshire County Council Draft Minerals Local Plan Consultation
As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved.
We own and manage over 1000 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.
Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide
for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost.
As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.
Approximately one quarter of priority UK BAP species are associated with woodland habitats.
Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.
Planning Policy
We note that you recognise that your consultation period overlaps with the publication of the revised NPPF and that subsequent drafts will reflect the new framework. The 2018 revision significantly improves the protection of ancient woodland with the revised policy set out in paragraph 175c:
...development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional
reasons58 and a suitable compensation strategy exists; and
Footnote 58 states:
For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat.
This is a significant change from the wording set out in Policy DM4: Protection and Enhancement of Biodiversity and Geodiversity which echoes the 2012 NPPF. We hope to see this updated in the next iteration of your plan as per your commitment set out on page nine of the draft.

It must be noted that the Planning Practice Guidance (PPG) gives equal protection to Plantations on Ancient Woodland Sites (PAWS) as it does to Ancient Semi-Natural Woodland (ASNW) (Paragraph:
021 Reference ID: 8-021-20140306). We are also expecting the PPG to be further updated to reflect the NPP revisions.
Allocated Sites
Planning authorities and inspectors increasingly act to prevent its direct destruction. However, the damage and impacts posed to ancient woods by nearby development are not so widely appreciated.
As such we are concerned to see that minerals activities have been allocated next to two ancient woodland sites, as set out in the table below. We request that every effort is made to appropriately buffer these woodlands with new planting of a minimum of 50m to protect their unique and irreplaceable nature. Please consult the Woodland Trust at the earliest opportunity in the event of any future applications on the site.
Site Allocation Nottinghamshire County Council's Draft Minerals Local Plan 2018

MP2r - Botany Bay
Retford Sand and gravel quarry
Adjacent Unmapped ancient woodland
Barnby Fox Covert*
(SK6676383259)
MP2s - Mill Hill (Near Barton in Fabis) Beeston Sand and gravel quarry
Adjacent Brandshill Wood -
ASNW**
(SK5307433430)
*Ancient woodland status of Barnby Fox Covert should be assessed by Natural England.
**Currently being added to the Ancient Woodland Inventory by Natural England.

Intensifying land uses adjacent to ancient woodland can have a significant impact upon the woodland in a number of different ways:
Increased activity such as through mineral extraction can result in: modified local hydrological regimes; vibration; noise and light pollution; vehicular collisions with wildlife; external activity visible from within the wood; an increase in wind-blown litter accumulation; and tree surgery or felling along the woodland edge for safety reasons or subsidence prevention.
Noise and light pollution interfere with interactions between species, affecting foraging and predation, reducing breeding success and thereby affecting on-going population viability.
Disturbance may, therefore, lead to species being eliminated from woods.
Vegetation clearance near to ancient woodland may affect woodland hydrology, increasing the likelihood of water-logging or drought and leading to loss of trees and changes in species composition. Soil compaction adjacent to woodland increases water run-off and soil erosion. It can cause severe damage to tree roots, leading to tree defoliation, crown dieback, and death.
The Trust asks that ancient woodland is considered as a key constraint in the future development of these sites and that the appropriate planted buffer is put in place. We would also take this opportunity to ask to be consulted on all forthcoming applications affecting ancient woodland.

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