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 over 1,250 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.

The Trust is concerned about site allocations MD2 and MD4 as they could lead to the
damage and loss of ancient woodland.

Planning Policy
National Planning Policy Framework (NPPF) paragraph 118 states that "planning
permission should be refused for development resulting in the loss or deterioration of
irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees
found outside ancient woodland, unless the need for, and benefits of, the development
in that location clearly outweigh the loss."

Natural England?s standing advice for Ancient Woodland and Veteran Trees1 states:
?Trees and woodland classed as ?ancient? or ?veteran? are irreplaceable. Ancient
woodland takes hundreds of years to establish and is considered important for its
wildlife, soils, recreation, cultural value, history and contribution to landscapes.?
Paragraph 5.2.4 of the UK Biodiversity Action Plan (UKBAP) includes objectives to
conserve, and, where practicable, enhance:

? the quality and range of wildlife habitats and ecosystems;
? the overall populations and natural ranges of native species;
1 https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protecti…
? internationally important and threatened species, habitats and ecosystems;
? species, habitats and natural and managed ecosystems characteristic of local areas;
and
? biodiversity of natural and semi-natural habitats where this has been diminished
over recent decades.

Section 40 of the Natural Environment and Rural Communities Act 2006 requires all
public authorities (including LPAs), in exercising their functions to have regard, so far as
is consistent with the proper exercise of those functions, to the purpose of conserving
biodiversity.

Impacts on Ancient Woodland
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.

Development in ancient woodland can lead to long-term changes in species
composition, particularly ground flora and sensitive fauna, i.e. nesting birds, mammals
and reptiles. Majorly adverse impacts would occur as a result of the removal of large
areas of woodland, much of which contains high quality, valuable trees, to make way for
construction works.

When land use is changed to a more intensive use such as in this situation plant and
animal populations are exposed to environmental impacts from outside of the
woodland. In particular, the habitats will become more vulnerable to the outside
influences, or edge effects, that result from the adjacent land?s change of use. These
detrimental edge effects can result in changes to the environmental conditions within
the woodland and consequently affecting the wood?s stable conditions. Detrimental
edge effects have been shown to penetrate woodland causing changes in ancient
woodland characteristics that extend up to three times the canopy height in from the
forest edges.

Creation of new areas of woodland or buffer zones around semi-natural habitats, and
more particularly ancient woodland, will help to reduce and ameliorate the impact of
damaging edge effects, serving to improve their sustainability. The size of the buffer is
dependent on the intensity of land use in the intervening matrix between ancient woods.
Natural England?s standing advice for Ancient Woodland and Veteran Trees states:
?Impacts of development nearby can include these effects on the trees and woodland,
and the species they support:
? compacting the soil around tree roots
? breaking up or destroying connections between woodland and other habitats
? reducing the amount of semi-natural habitats (like parks) next to ancient woodland
? changing the water table or drainage
? increasing the amount of pollution, including dust
? increasing disturbance to wildlife from additional traffic and visitors
? increasing light pollution
? increasing damaging activities like flytipping and the impact of domestic pets
? changing the landscape character of the area.?

We have already seen the damage that development can have on ancient woodland with the recent housing development next to the Woodland Trust Callands Wood in Warrington. It is vital that development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and Natural England recommend ?leaving an appropriate buffer zone of semi-natural habitat between the development and the ancient woodland or tree (depending on the size of development,
a minimum buffer should be at least 15 metres).?

The size of the site allocations MD2 and MD4 suggests that large scale development could
potentially take place. The minimum 15m buffer recommendation to all development is
not effective in ensuring that ancient woodland within and/or adjacent is not affected by potential future development. In this instance we would recommend buffering of 50m.

Conclusion
The Trust is concerned about the potentially adverse impacts that the proposed site
allocations MD2 and MD4 will have in relation to areas of ancient woodland within and/or adjacent to
site allocations. Ancient woodland should not be included in areas that are allocated for
development, whether for Residential, leisure or community purposes as this leaves
them open to the impacts of development.

The Woodland Trust objects to the inclusion of these site allocations as they are
likely to cause damage and/or loss to areas of ancient woodland within or adjacent to
their boundaries. For this reason we believe the sites detailed below are unsound
and should not be taken forward. Secondary woodland should also be retained to
ensure that ecological networks are maintained and enhanced.

We hope you find our comments to be of use to you. The Woodland Trust is happy to
provide any additional information or support regarding the protection of ancient
woodland.

If you require any further information regarding points raised within this document, then
please do not hesitate to contact us.

MD2
Ancient woodland and veteran trees affected by this site allocation:
Woodland Trust ASNW, Lumb Brook Valley North, SJ627849

3 ATI trees
ID 153,345 ancient dead wild cherry
ID 153,354 veteran wild cherry
ID 153,353 veteran wild cherry

Woodland Trust Wood, Grappenhall Heys, SJ627858

MD4
Woodland Trust Radley Plantation, 16915