Object

Representation ID: 99479

Received: 16/12/2022

Respondent: Dr L David Ormerod

Legally compliant? No

Sound? No

Duty to co-operate? No

Protection of Woodland
In Policy [paragraph] 8.1, it states, "The Climate Change Act 2008 sets up a framework for the UK to achieve its longterm goals of reducing greenhouse gas emissions and to ensure that steps are taken towards adapting to the impacts of climate change. That Act also introduced a requirement into the Planning and Compulsory Purchase Act, 2004, for local planning authorities to address climate change in preparing Local Plans. In 2019, the Climate Change Act was amended to commit the UK government by law to reduce greenhouse gas emissions by at least 100% of 1990 levels (net zero) by 2050. The government's Net Zero Strategy, Build Back Greener (2021), sets out policies and proposals for decarbonising all sectors of the UK economy to meet net zero target by 2050.

Policy [paragraph] 8.3 adds, "Forestry and woodlands act as carbon sinks and capture greenhouse gas emissions. In addition, habitat creation and the expansion of existing habitats can increase the resilience of the natural environment to cope with climate change." It goes on to support these objectives in the reclamation of mining sites.

Policy MW3 states, "Proposals for new minerals and waste developments (including extensions to existing sites) will therefore be expected to: (f) take opportunities to incorporate trees, retain existing trees and include measures to assist habitats and species to adapt to the potential effects of climate change wherever change is possible."

The NMWLP establishes 'ancient woodland' and 'veteran trees' as landscape features that will be strongly protected. Development Management Policy OM 8.23, (NMWJP, Preferred Options, July 2019) for example, states, "There are also important areas of ancient woodland across Norfolk, often with veteran trees ……All of these landscape features will be strongly protected from any adverse impacts arising from minerals and waste management development." [paragraph 6.24 of Pre-Submission document]

To help allay Net Zero, the UK government is dedicated to plant 1M acres of trees by 2050, increasing national tree cover from 14.5 to 17.5 %. In September 2019, the Norfolk County Council committed to planting 1 million trees over the next 5 years. In the Cabinet Members Delegated Decision Paper on the Preferred Options Consultation, dated December 10th, 2019, there was an important statement. Under a heading, Policy MP13 Silica Sand Area of Search AOS E and Policy MP2, it was stated, "(this) suggests a significant policy shift in the important roles that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover, with additional recreational opportunities. An elevated status needs to be given this in the planning balance as to whether an Area of Search should be designated at Shouldham. The Borough Council view is that the County Council should remove the AOS for this reason."

It continues, "Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a) refers to 'ancient woodland.' In view of the County Council decision referred to above, it would be appropriate to delete the word "ancient' leaving an enhanced level of protection to woodland in general." The next sentence refers to this new protection of woodland in the decision to remove AOS E from the preferred options site selection.

This change of definition is yet to find its way into the NMWLP document. It should be modified to affect this change.

Soundness: Not Effective, Not Positively Prepared, Not Consistent with National Policy