Sandwell Local Plan - Reg 19 Publication

The Council’s tree canopy cover is just 18.1 per cent, which contrasts to an average of 38 per cent across the EU. Therefore, we believe that woodland creation and conservation should be a major priority for the LP. We salute the Council’s ambition to oversee a six per cent canopy cover uplift, which should be informed by extensive opportunity mapping we funded via the former Black Country Consortium,1 but this inevitably comes with caveats.

Principally, it is key to select the right tree for the right place and, while we recognise the role non-native trees will play in meeting near-term targets, as well as the ability of some to confront specific concerns like air pollution on busy streets, they should be minimised both to prevent the introduction of pests and diseases through tree importation (viz. biosecurity risk) and to offer the greatest ability for already-existing flora and fauna to benefit. The maximum possible proportion of new trees should be native, and UK and Ireland Sourced and Grown (UKISG).2 Not only are some pests hazardous to human health, but supporting local nurseries and tree growers confers an economic benefit. The overall ambition should be for a canopy cover of 30 per cent in new developments.

It is essential that the climate and nature crises are addressed jointly, with trees’ remarkable ability to fight each recognised by the LP. Resolving the nature crisis resolves the climate crisis, but this is not necessarily true the other way around. So, while encouraged by the LP’s references to trees’ biodiversity contribution, we would like it to go further, assigning definite BNG targets while grasping future opportunities afforded by Local Nature Recovery Strategies (LNRSes) required by the Environment Act 2021. Complementing these should be a robust commitment to protection for individual AVTs where identified.

Specifically, we would like to see the LP expand on these environmental principles in the following ways.

• Protection of valued habitats must be at the heart of the LP. In particular, irreplaceable habitats, including AVTs, must be
protected from loss and damage. To achieve this, the LP should:
• Give weight to the relevant LNRS as it is refined. This should identify ancient woodland sites to ensure that development
is not allocated in close proximity to ancient woodland.
• For AVTs, the LP should encourage their recording on the Ancient Tree Inventory3 as a matter of course and consider
locations where it might be suitable to place a Tree Preservation Order on any ancient, veteran, or notable trees recorded.
• Adhere to appropriate buffering standards for ancient woodland and AVTs:
▪ Preserve a 50-metre buffer4 between new developments and ancient woodland. Still greater buffers may be needed
for major engineering work or disruptive post-construction activities. An absolute commitment to safeguard ancient
woodland is welcome, but should be accompanied by buffering.
▪ For AVTs, ensure a Root Protection Area that is 15 times the trunk’s diameter or extends five metres beyond the
canopy, whichever is greater.
▪ Assess the nitrogen impact of ammonia-emitting developments on ancient woodland less than five kilometres distant.
• For non-AVTs, adopt the Bristol Tree Replacement Standard5 with respect to felling and specify replacement trees be planted no more than
12 times the distance of the original tree’s trunk diameter, to correspond with root extent area.

These measures will help safeguard the ecological integrity of ancient woodland and the health of AVTs in the face of development pressures.

The LP must go beyond minimum requirements for BNG and be an example of best practice:
• The LP should require all development projects to deliver 20 per cent BNG minimum.6
• Consideration should be given to the quantum of other investment sources (public and private) which will be needed in order to meet these
targets.
• The LP should require BNG units to be maintained for a minimum of 50 years, not just the 30 set out in the Environment Act.
▪ This is particularly important for woodland creation, as it takes many decades for new woods to reach maturity and their full ecological
potential.
▪ BNG should deliver a rich mix of habitats including native woodland, informed by LNRSes.
▪ Habitat creation funded through other mechanisms (such as public funds) should also be maintained in the long term.

The LP should give strong weight to LNRSes for development site allocation at a local level:
• This will be essential to embed avoidance of impacts to existing sensitive natural assets, by providing a ‘spatial’ element to site allocation
decisions. It is vital that development is allocated in a way which protects important sites for nature, maintains ecological integrity and
maximises potential enhancements from land in recovery.
• Once a site has been allocated in a local plan, it is more likely to receive planning permission, so it is essential to embed ecologically
coherent criteria for spatial prioritisation at the framework level.
• LNRSes should also be used to inform priority locations for the provision of green infrastructure, and habitat creation and enhancement through BNG.

• The LP should set standards for high-quality green infrastructure for development:
• Major developments should provide five UKISG-compliant trees per dwelling or per 1,000m2 of non-residential floorspace.
• Similarly, no one should be more than 300 metres from the nearest natural green space, with safe and accessible routes.
• Consideration should also be given to the Woodland Trust’s Access to Woodland Standard which aspires that everyone
should have a small
wood of at least two hectares in size within 500 metres of their home, and a larger wood of at least 20 hectares in size
within four kilometres of where they live.
• A strong tree retention standard7 for responsible development must also be embraced, ensuring the preservation of trees
and their ecological benefits. This standard will require a thorough tree survey during initial site investigations, categorising
trees by their health and quality (A, B, C or U), and submitting a clear Tree Retention Plan. Additionally, it will mandate the
creation of a Tree Protection Plan, safeguarding tree root systems and establishing construction exclusion zones (CEZs).

In summary, we consider that the Environmental Principles must be treated as a foundational component of the LP. As part of incorporating the principles, the LP must support the protection of sensitive natural assets, such as AVTs; be an exemplar of emerging BNG practice; and set high standards for the retention and provision of trees within developments.

The Council’s tree canopy cover is just 18.1 per cent, which contrasts to an average of 38 per cent across the EU. Therefore, we believe that woodland creation and conservation should be a major priority for the LP. We salute the Council’s ambition to oversee a six per cent canopy cover uplift, which should be informed by extensive opportunity mapping we funded via the former Black Country Consortium,1 but this inevitably comes with caveats.

Principally, it is key to select the right tree for the right place and, while we recognise the role non-native trees will play in meeting near-term targets, as well as the ability of some to confront specific concerns like air pollution on busy streets, they should be minimised both to prevent the introduction of pests and diseases through tree importation (viz. biosecurity risk) and to offer the greatest ability for already-existing flora and fauna to benefit. The maximum possible proportion of new trees should be native, and UK and Ireland Sourced and Grown (UKISG).2 Not only are some pests hazardous to human health, but supporting local nurseries and tree growers confers an economic benefit. The overall ambition should be for a canopy cover of 30 per cent in new developments.

It is essential that the climate and nature crises are addressed jointly, with trees’ remarkable ability to fight each recognised by the LP. Resolving the nature crisis resolves the climate crisis, but this is not necessarily true the other way around. So, while encouraged by the LP’s references to trees’ biodiversity contribution, we would like it to go further, assigning definite BNG targets while grasping future opportunities afforded by Local Nature Recovery Strategies (LNRSes) required by the Environment Act 2021. Complementing these should be a robust commitment to protection for individual AVTs where identified.

Specifically, we would like to see the LP expand on these environmental principles in the following ways.

• Protection of valued habitats must be at the heart of the LP. In particular, irreplaceable habitats, including AVTs, must be
protected from loss and damage. To achieve this, the LP should:
• Give weight to the relevant LNRS as it is refined. This should identify ancient woodland sites to ensure that development
is not allocated in close proximity to ancient woodland.
• For AVTs, the LP should encourage their recording on the Ancient Tree Inventory3 as a matter of course and consider
locations where it might be suitable to place a Tree Preservation Order on any ancient, veteran, or notable trees recorded.
• Adhere to appropriate buffering standards for ancient woodland and AVTs:
▪ Preserve a 50-metre buffer4 between new developments and ancient woodland. Still greater buffers may be needed
for major engineering work or disruptive post-construction activities. An absolute commitment to safeguard ancient
woodland is welcome, but should be accompanied by buffering.
▪ For AVTs, ensure a Root Protection Area that is 15 times the trunk’s diameter or extends five metres beyond the
canopy, whichever is greater.
▪ Assess the nitrogen impact of ammonia-emitting developments on ancient woodland less than five kilometres distant.
• For non-AVTs, adopt the Bristol Tree Replacement Standard5 with respect to felling and specify replacement trees be planted no more than
12 times the distance of the original tree’s trunk diameter, to correspond with root extent area.

These measures will help safeguard the ecological integrity of ancient woodland and the health of AVTs in the face of development pressures.

The LP must go beyond minimum requirements for BNG and be an example of best practice:
• The LP should require all development projects to deliver 20 per cent BNG minimum.6
• Consideration should be given to the quantum of other investment sources (public and private) which will be needed in order to meet these
targets.
• The LP should require BNG units to be maintained for a minimum of 50 years, not just the 30 set out in the Environment Act.
▪ This is particularly important for woodland creation, as it takes many decades for new woods to reach maturity and their full ecological
potential.
▪ BNG should deliver a rich mix of habitats including native woodland, informed by LNRSes.
▪ Habitat creation funded through other mechanisms (such as public funds) should also be maintained in the long term.

The LP should give strong weight to LNRSes for development site allocation at a local level:
• This will be essential to embed avoidance of impacts to existing sensitive natural assets, by providing a ‘spatial’ element to site allocation
decisions. It is vital that development is allocated in a way which protects important sites for nature, maintains ecological integrity and
maximises potential enhancements from land in recovery.
• Once a site has been allocated in a local plan, it is more likely to receive planning permission, so it is essential to embed ecologically
coherent criteria for spatial prioritisation at the framework level.
• LNRSes should also be used to inform priority locations for the provision of green infrastructure, and habitat creation and enhancement through BNG.

• The LP should set standards for high-quality green infrastructure for development:
• Major developments should provide five UKISG-compliant trees per dwelling or per 1,000m2 of non-residential floorspace.
• Similarly, no one should be more than 300 metres from the nearest natural green space, with safe and accessible routes.
• Consideration should also be given to the Woodland Trust’s Access to Woodland Standard which aspires that everyone
should have a small
wood of at least two hectares in size within 500 metres of their home, and a larger wood of at least 20 hectares in size
within four kilometres of where they live.
• A strong tree retention standard7 for responsible development must also be embraced, ensuring the preservation of trees
and their ecological benefits. This standard will require a thorough tree survey during initial site investigations, categorising
trees by their health and quality (A, B, C or U), and submitting a clear Tree Retention Plan. Additionally, it will mandate the
creation of a Tree Protection Plan, safeguarding tree root systems and establishing construction exclusion zones (CEZs).

In summary, we consider that the Environmental Principles must be treated as a foundational component of the LP. As part of incorporating the principles, the LP must support the protection of sensitive natural assets, such as AVTs; be an exemplar of emerging BNG practice; and set high standards for the retention and provision of trees within developments.

The Council’s tree canopy cover is just 18.1 per cent, which contrasts to an average of 38 per cent across the EU. Therefore, we believe that woodland creation and conservation should be a major priority for the LP. We salute the Council’s ambition to oversee a six per cent canopy cover uplift, which should be informed by extensive opportunity mapping we funded via the former Black Country Consortium,1 but this inevitably comes with caveats.

Principally, it is key to select the right tree for the right place and, while we recognise the role non-native trees will play in meeting near-term targets, as well as the ability of some to confront specific concerns like air pollution on busy streets, they should be minimised both to prevent the introduction of pests and diseases through tree importation (viz. biosecurity risk) and to offer the greatest ability for already-existing flora and fauna to benefit. The maximum possible proportion of new trees should be native, and UK and Ireland Sourced and Grown (UKISG).2 Not only are some pests hazardous to human health, but supporting local nurseries and tree growers confers an economic benefit. The overall ambition should be for a canopy cover of 30 per cent in new developments.

It is essential that the climate and nature crises are addressed jointly, with trees’ remarkable ability to fight each recognised by the LP. Resolving the nature crisis resolves the climate crisis, but this is not necessarily true the other way around. So, while encouraged by the LP’s references to trees’ biodiversity contribution, we would like it to go further, assigning definite BNG targets while grasping future opportunities afforded by Local Nature Recovery Strategies (LNRSes) required by the Environment Act 2021. Complementing these should be a robust commitment to protection for individual AVTs where identified.

Specifically, we would like to see the LP expand on these environmental principles in the following ways.

• Protection of valued habitats must be at the heart of the LP. In particular, irreplaceable habitats, including AVTs, must be
protected from loss and damage. To achieve this, the LP should:
• Give weight to the relevant LNRS as it is refined. This should identify ancient woodland sites to ensure that development
is not allocated in close proximity to ancient woodland.
• For AVTs, the LP should encourage their recording on the Ancient Tree Inventory3 as a matter of course and consider
locations where it might be suitable to place a Tree Preservation Order on any ancient, veteran, or notable trees recorded.
• Adhere to appropriate buffering standards for ancient woodland and AVTs:
▪ Preserve a 50-metre buffer4 between new developments and ancient woodland. Still greater buffers may be needed
for major engineering work or disruptive post-construction activities. An absolute commitment to safeguard ancient
woodland is welcome, but should be accompanied by buffering.
▪ For AVTs, ensure a Root Protection Area that is 15 times the trunk’s diameter or extends five metres beyond the
canopy, whichever is greater.
▪ Assess the nitrogen impact of ammonia-emitting developments on ancient woodland less than five kilometres distant.
• For non-AVTs, adopt the Bristol Tree Replacement Standard5 with respect to felling and specify replacement trees be planted no more than
12 times the distance of the original tree’s trunk diameter, to correspond with root extent area.

These measures will help safeguard the ecological integrity of ancient woodland and the health of AVTs in the face of development pressures.

The LP must go beyond minimum requirements for BNG and be an example of best practice:
• The LP should require all development projects to deliver 20 per cent BNG minimum.6
• Consideration should be given to the quantum of other investment sources (public and private) which will be needed in order to meet these
targets.
• The LP should require BNG units to be maintained for a minimum of 50 years, not just the 30 set out in the Environment Act.
▪ This is particularly important for woodland creation, as it takes many decades for new woods to reach maturity and their full ecological
potential.
▪ BNG should deliver a rich mix of habitats including native woodland, informed by LNRSes.
▪ Habitat creation funded through other mechanisms (such as public funds) should also be maintained in the long term.

The LP should give strong weight to LNRSes for development site allocation at a local level:
• This will be essential to embed avoidance of impacts to existing sensitive natural assets, by providing a ‘spatial’ element to site allocation
decisions. It is vital that development is allocated in a way which protects important sites for nature, maintains ecological integrity and
maximises potential enhancements from land in recovery.
• Once a site has been allocated in a local plan, it is more likely to receive planning permission, so it is essential to embed ecologically
coherent criteria for spatial prioritisation at the framework level.
• LNRSes should also be used to inform priority locations for the provision of green infrastructure, and habitat creation and enhancement through BNG.

• The LP should set standards for high-quality green infrastructure for development:
• Major developments should provide five UKISG-compliant trees per dwelling or per 1,000m2 of non-residential floorspace.
• Similarly, no one should be more than 300 metres from the nearest natural green space, with safe and accessible routes.
• Consideration should also be given to the Woodland Trust’s Access to Woodland Standard which aspires that everyone
should have a small
wood of at least two hectares in size within 500 metres of their home, and a larger wood of at least 20 hectares in size
within four kilometres of where they live.
• A strong tree retention standard7 for responsible development must also be embraced, ensuring the preservation of trees
and their ecological benefits. This standard will require a thorough tree survey during initial site investigations, categorising
trees by their health and quality (A, B, C or U), and submitting a clear Tree Retention Plan. Additionally, it will mandate the
creation of a Tree Protection Plan, safeguarding tree root systems and establishing construction exclusion zones (CEZs).

In summary, we consider that the Environmental Principles must be treated as a foundational component of the LP. As part of incorporating the principles, the LP must support the protection of sensitive natural assets, such as AVTs; be an exemplar of emerging BNG practice; and set high standards for the retention and provision of trees within developments.