The following is the submission from the Woodland Trust. We are most grateful to the Trust for allowing us to publish it.
Please note the formatting errors are ours in converting it to web format, and not the Trusts.
Worthing Borough Council
Planning Section
Portland House
Richmond Road
Worthing
West Sussex
BN11 1LF
Our Ref: GB
8th February 2002
Dear Sirs,
West Durrington, Planning Application Reference: WB/01/0101
The comments that follow are delivered on behalf of the United Kingdom’s leading woodland conservation charity. We achieve our purposes through a combination of acquiring woodland and sites for planting and through advocacy of the importance of protecting ancient woodland, enhancing its biodiversity, expanding woodland cover and increasing public enjoyment. We own over 1,100 sites across the country, covering around 18,000 hectares (45,000 acres) and we have 250,000 members and supporters.
In July 1998 we published Keeping Woodland Alive, setting out priorities for the future. One of our four priorities is to ensure that there should be no further loss of ancient woodland.
Ancient woodland is, by definition, an irreplaceable natural resource and takes
century’s, even millennia to evolve. As the habitat most representative of original,
natural, stable conditions, ancient woodland is home to more threatened species than
any other habitat in the UK. This is supported by the UK Biodiversity Action Plan, which
identifies that broadleaved woodland supports almost twice as many UK Biodiversity
Action Plan species as any other habitat e.g. more than twice as many as chalk
grassland and almost three times as many as lowland heath land. It contains a unique
assemblage of plants and animals, and has ecological, landscape, amenity, historical
and cultural associations.
* Ancient woodland in terms of biodiversity is the most valuable habitat we have in the UK.
* Three thousand years ago, it covered the vast majority of the land area of the UK.
* It now covers just 2 per cent.
* Of the ancient woodland on the Ancient Woodland Inventory, which existed in the 1930s, around 50 per cent has now been lost, especially in the last 40 years mostly due to coniferisation, encroachment by agriculture and development.
* 85 % of ancient woodland currently has no protection under wildlife legislation, as only 15% has the status of a Site of Special Scientific Interest
UK Government guidance emphasises the importance of conserving the special characteristics of ancient woodlands because of their value for biodiversity and as part of the historic environments. It is recognised that the area of ancient woodland has declined and become increasingly fragmented and the Government states that it aims to halt these trends by not allowing the reduction of the ancient woodland area. The Government also recognises the importance of enhancing the protection of ancient woodland by expanding and linking them to others.
For the above reasons the Woodland Trust will always become concerned if there are development proposals of any type which might threaten ancient woodland. We particularly note that the application submitted for development of 875 houses at West Durrington would have a material effect on various areas of ancient woodland including the direct loss to the Titnore Lane road improvements of 1.5 hectares. We comment further as following [location references are taken from the Environmental Statement prepared by CPM].
1 The Trust recognises that, particularly in the SE/south counties, there is an
unavoidable requirement for additional housing land. If it is accepted that
there are insufficient brownfield sites in the Worthing area to meet this
demand, inevitably there must therefore a release of greenfield sites. No
doubt, there will be opposition for a multitude of reasons to any such
proposals. However, as a conservation organisation, we believe that the
environmental heritage of the UK can and must be protected, and we see
this Planning Application as a prime example where insufficient thought has
gone into the protection of valuable habitats. The consequences would be:-
* The widening of Titnore Lane to accommodate the considerable additional traffic generated by this development causing direct loss of ancient woodland.
* The loss of ancient woodland to the new site/feeder roads forming the development
* The positioning of commercial and residential buildings too close to the woodland resulting in insufficient buffering of remaining ancient woodland.
2 Titnore Lane already clearly suffers from excessive vehicular use without the
additional traffic to be generated by the proposed development. However,
why does this route need to be the primary access to this site when it
would be possible to create a direct new link to the A27 to the north of the
site – something that would be viable given the size of this development site
and less far damaging to the environment? Titnore Lane is a rural road that
has already reached maximum traffic capacity and is not suited for
widening/ improvement without giving rise to a significant and unacceptable
change to the local landscape. The loss of 1.5 ha of trees to produce a road
that does not even then meet County standards is unacceptable – this
unsatisfactory compromise suggests the value of the contiguous ancient
woodland was recognised by the Council but without proper examination of alternatives.
3 The proposed isolated business park area on three sides adjoins woodland of ancient origin [ES reference W3, W4, and W6].
Plant and animal populations are exposed to environmental impacts from outside the woodland site and these are associated with intensive use of adjacent land. In particular, the habitats will become more vulnerable to outside influences resulting from the adjacent change of use. Detrimental edge effects penetrate woodland and it is known that changes in microclimate extend up to three times the canopy height in from the forest edges.
It follows that a change of use of the adjacent land away from open
space/agriculture will be detrimental to the biodiversity of the woodland.
Buffer zones around semi-natural habitats and ancient woodland in particular
are therefore essential to reduce the impact of damaging edge effects if
their sustainability is to be improved. This particularly applies if urban
development [viz. buildings/roads etc.] is allowed to encroach closer to the
woodland edges, it being a requisite that as larger buffer zone as possible is
maintained around the woodland edge.
Whilst the western part of W3 might be already be partially degraded, the other contiguous woodlands will suffer edge effect damage if built development is permitted within 30 metres of the woodland edge.
4 The Avenue [site feeder road] off Titnore Lane is similarly located immediately north of ancient woodland [ES reference W8]. The same comments as in 3 above therefore apply.
5 Residential areas 5 & 6 both have ancient woodland immediately to the north and south boundaries [ES reference W1, W8 & W9] and again the woodland needs to be buffered by 30 metre wide plus green strips.
6 The Avenue [site feeder road] passes across the middle of ancient woodland [ES reference W10] resulting in loss of part.
7 The path intended to link the Business Park and the residential areas, passes either through or is contiguous to ancient woodland for most of its length. Construction of this route will result in the direct loss of ancient woodland, but also in the longer term use will result in the degradation of adjoining woodland.
We do not accept that the ES evaluation of any of the above impacts on ancient woodland is correctly described as ‘minor’ [or in one case ‘negligible’]. We cannot see how the loss of a diminishing UK habitat now reduced to covering 2% of the countryside can be so described.
The potential damage to this ancient woodland could be avoided if the Planning Authority insisted upon a redesign of this scheme. It would seem that both Government Guidelines relating to the protection of ancient woodland and the Council’s own woodland protection policies are to be ignored if this development is approved in it’s present form.
The Woodland Trust Objects in the strongest possible terms to the current proposals.
Yours faithfully
Graham Bradley
Planning Casework Officer
Woods Under Threat
Founded in 1972 by Kenneth Watkins, OBE. Registered Charity No 294344. A non-profit making company limited by guarantee. Registered in England No 1982873. The Woodland Trust logo is a trademark of The Woodland Trust.
