Medway Local Plan (Regulation 18, 2023)

We support the goal of integrating action on climate change and nature recovery into the Local Plan. The climate crisis is paralleled by a nature crisis and we need solutions that will tackle both.

A rapid increase in the rate of woodland creation has been proposed by the UK’s Committee on Climate Change (CCC), to provide a key mechanism to lock up carbon in trees and soils, provide an alternative to fossil fuel energy and resource-hungry building material, increase resilience to the impact of climate change, and to stem the declines in biodiversity. The Woodland Trust supports the CCC’s recommended an increase in UK woodland cover from its current 13% of land area to at least 19% by 2050 to tackle this country’s biodiversity and climate crises. More information can be found in the Trust’s 2020 publication The Emergency Tree Plan.

Urban trees and hedgerows help mitigate the impacts of climate change, delivering natural cooling in urban heat islands through transpiration as well as providing shelter and shade, and contributing to sustainable urban drainage systems. They also make a valuable contribution to the quality of the public realm, helping reduce air, noise and light pollution and improve people’s mental health.

We recommend including specific policy in support of new tree planting, hedgerows and urban woodland creation in the Local Plan. We recommend setting a % target for tree canopy cover, to be pursued through the retention of important trees, appropriate replacement of trees lost through development, ageing or disease and by new planting to support green infrastructure. This will complement the emerging requirements for Biodiversity Net Gain and the Local Nature Recovery Strategy.

We encourage the inclusion of green infrastructure as part of essential infrastructure and connectivity and urge a landscape-scale approach to maximise the benefits for nature and people. Design guidance should incorporate the protection and extension of green infrastructure including support for SuDS in all new developments, and encouragement of green links, such as tree lines and hedgerows, to frame residential areas and connect existing habitats.

In addition, trees and hedgerows help mitigate the impacts of climate change, delivering natural cooling in urban heat islands through transpiration as well as providing shelter and shade, and contributing to sustainable urban drainage systems. They also make a valuable contribution to the quality of the public realm, helping reduce air, noise and light pollution and improve people’s mental health.

We recommend including specific policy in support of new tree planting, hedgerows and urban woodland creation. We recommend setting a target for tree canopy cover, ideally of 30 per cent and of at least 20 per cent, to be pursued through the retention of important trees, greater than 1:1 replacement of trees lost through development, ageing or disease and by new planting to support green infrastructure.

We encourage the integration of tree planting into new walking and cycling routes, to provide shelter and shade and to maximise the potential of these new green corridors for habitat connectivity.

We support the principle that residential developments should have access to the natural environment, including to woodland. • Everyone should have access to nature-rich green space in walking distance from where they live.

We recommend adopting policy standards for residential developments that support access to the natural environment and woodland for informal recreation.

Natural England’s Accessible Natural Green Space Standard recommends that all people should have accessible natural green space:
– Of at least two hectares in size, no more than 300m (five minutes’ walk) from home.
– At least one accessible 20-hectare site within 2km of home.
– One accessible 100-hectare site within 5km of home.
– One accessible 500-hectare site within 10km of home.
– A minimum of one hectare of statutory local nature reserves per 1,000 people.

The Woodland Trust has developed a Woodland Access Standard to complement the Accessible Natural Green Space Standard. This recommends that:
– That no person should live more than 500m from at least one area of accessible woodland of no less than 2ha in size.
– That there should also be at least one area of accessible woodland of no less than 20ha within 4km (8km round trip) of people’s homes.

We recommend adding a reference to the green economy alongside green tourism, in particular silviculture, once an important part of Kent's economy. We need a new generation of tree nurseries supplying UK sourced and grown tree stock for new planting, to support biodiversity and resilience.

We support the objective to encourage the re-use and redevelopment of previously-developed land. Using an Urban Greening Factor approach can complement biodiversity net gain on urban sites with low baseline biodiversity.

Such redevelopment should seek to preserve existing mature trees and protect existing habitats on biodiverse brownfield sites. High density housing should seek to accommodate trees along boundaries, paths and in areas of public space.

Design standards should presume the retention of existing trees, promote connectivity in location of new planting and prioritise suitable species selection including UK sourced & grown tree stock for biosecurity.

We support the objective to encourage the re-use and redevelopment of previously-developed land. Such redevelopment should seek to preserve existing mature trees and protect existing habitats on biodiverse brownfield sites. It is also important that urban sites have good green infrastructure. High density housing should seek to accommodate trees along boundaries, paths and in areas of public space. We recommend a requirement to retain and incorporate existing trees, plant more and maximise the use of green walls, urban hedgerows, green roofs and SUDS.

Development which would result in the loss of ancient woodland, aged or veteran trees should not be permitted. The Woodland Trust would object to the allocation for development of any sites which have a direct impact on or are adjacent to identified areas of Ancient Woodland.

The Ancient Tree Inventory (ATI) for the area may be incomplete. We recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF for the protection of irreplaceable habitats.

The Woodland Trust previously commented on the HIF programme proposals for the Hoo Peninsula. We were broadly supportive of plans for increased green infrastructure and new areas of woodland to buffer and reconnect SSSI and ancient woodland sites. The need for such buffering and connectivity remains vital to protect the landscape and delivery nature recovery goals.

Development which would result in the loss of ancient woodland, aged or veteran trees should not be permitted. The Woodland Trust would object to the allocation for development of any sites which have a direct impact on or are adjacent to identified areas of Ancient Woodland.

The Ancient Tree Inventory (ATI) for the area may be incomplete. We recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF for the protection of irreplaceable habitats.

In addition to the constraints noted above, there are several areas of ancient woodland in the Medway rural hinterland. Development which would result in the loss of ancient woodland, aged or veteran trees should not be permitted. The Woodland Trust would object to the allocation for development of any sites which have a direct impact on or are adjacent to identified areas of Ancient Woodland.

The Ancient Tree Inventory (ATI) for the area may be incomplete. We recommend an exercise to complete the ATI (which lists ancient, veteran and notable trees outside woods) across sites allocated or proposed to be allocated for development, in order to comply with the requirements of the NPPF for the protection of irreplaceable habitats.