Biodiversity – Ancient Woodland Objection
Submitted to Wealden District Council by Sue McRae on behalf of the Horstedpond Farm Action Group (HFAG)
7 December 2022
Castlefort Homes proposes to build 400 homes on the fields of Horstedpond Farm at the southern edge of Uckfield. At the centre of Horstedpond Farm is a small complex of five residences, including Horstedpond House, a Grade II-listed building, and three converted agricultural buildings also of historical value. At the average of 2.28 people per dwelling, the existing 10 residents living in the enclave would have 900 new neighbours if the proposed project went ahead.
This Horstedpond Farm Action Group (HFAG) objection to the housing project that Castlefort Homes is proposing is focused on the irreparable damage that the scheme would cause to the adjacent ancient woodlands. The parcels of ancient woodland nearest to Horstedpond Farm are Park Wood, which borders the farm to the east, and Horstedpond Wood, which borders it to the south.
Both Natural England and the Forestry Commission recognise the special characteristics of ancient woodland. They jointly define it as follows: “Ancient woodland takes hundreds of years to establish and is … an irreplaceable habitat. It is a valuable natural asset important for wildlife, including rare and threatened species; carbon capture and storage; contributing to the seed bank and genetic diversity; recreation, health and wellbeing; and its cultural, historical and landscape value. It has been wooded continuously since at least 1600 AD.”
Furthermore, ancient semi-natural woodland (ASNW) “is mainly made up of trees and shrubs native to the area, usually arising from natural regeneration”.
ADVERSE HUMAN IMPACT
Both Horstedpond Wood and Park Wood are designated ancient semi-natural woodlands on Natural England’s Ancient Woodland Inventory (AWI). They are also listed in Section 41 of the Natural Environment & Rural Communities (NERC) Act 2006 as Habitat of Principal Importance. This listing places a legal obligation on public bodies in England to have regard to the types of habitat which are of the greatest conservation importance whilst carrying out their duties and having a general regard for protecting all biodiversity.
Another body, the Woodland Trust, has strongly objected to the proposed Horstedpond Farm development, not least because of the adverse impact it would have on the two adjacent ancient woodlands. Its objection states “The Trust objects to this planning application on the basis of potential deterioration and detrimental impact to Horstedpond Wood and Park Wood, two areas designated by Natural England as ASNW.”
The Woodland Trust objection points out that humans and their pets can cause disturbance to breeding birds, vegetation damage, trampling, litter and fire damage. Plus, the possible influx of a large number of new residents in what is a relatively small area raises issues of noise, light and dust pollution. Adverse hydrological impacts can occur where the introduction of hard-standing areas and water run-offs affect the quality and quantity of surface and ground water. This can result in the introduction of harmful pollutants/contaminants into the woodland, and a change in drainage conditions.
The flood risk report commissioned by the Horstedpond Farm developer states that there would be a net gain of 6.61 hectares of impermeable surfaces if the proposed project goes ahead – and that Sustainable Urban Drainage Systems (SuDS) should not be located within the ancient woodland buffer zone.
Paragraph 180 of the National Planning Policy Framework (NPPF) states “When determining planning applications, local planning authorities should apply the following principles:
- c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists;”
Footnote 63 defines exceptional reasons as follows: “For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat.”
HFAG believes there is no wholly exceptional reason for the proposed development at Horstedpond Farm and, as such, this project should be refused on the grounds it does not comply with national planning policy.
When land use is intensified, such as in this situation where a large housing development is proposed, woodland plant and animal populations are exposed to environmental impacts from the outside of a woodland. In particular, the habitats become more vulnerable to the outside influences, or edge effects, that result from the adjacent land’s change of use. These can impact cumulatively on woodland, which is more damaging than individual effects.
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.
Buffer zones can be used to establish distance between the development and habitat, which help to reduce harmful impacts, and paragraph 4.3.2 of the Preliminary Ecological Appraisal consultancy document submitted by the developer as part of the Horstedpond Farm planning application states “in respect to both the ancient woodland recognised on the AWI and the woodland within the site which likely qualifies as ancient woodland, it is strongly recommended that no works associated with the proposed development be undertaken within a distance of less than 15m from the woodland edge”.
The Woodland Trust has stated that such a buffer zone would be totally inadequate for a development as large as the one proposed. Instead, Woodland Trust calls for a buffer zone of at least 50 metres in width, as a precautionary principle. “Unless the developer can clearly demonstrate that a smaller buffer will suffice”, a 50-metre zone, reports the Trust, would prevent adverse impacts such as pollution and disturbance and ensure avoidance of root damage.
This requirement for an increased size buffer zone is backed up by Natural England and Forestry Commission’s standing advice, i.e. that “the proposal should have a buffer zone of at least 15 metres from the boundary of the woodland to avoid root damage (known as the root protection area). Where assessment shows other impacts are likely to extend beyond this distance, the proposal is likely to need a larger buffer zone.”
TREELINE ANCIENT WOODLAND
The Preliminary Ecological Appraisal (PEA) survey points out that several other woodland parcels within the Horstedpond Farm site are also likely to qualify as Ancient Woodland. One of these is between field boundaries within the south-west corner of the farm while another is along the northern farm boundary running parallel to Ridgewood Stream and forming a field boundary towards the eastern extent of the farm.
Paragraph 4.3.7 of the PEA survey states “Although not listed on Natural England’s Ancient Woodland Inventory (AWI), given the age, structure, quality and condition of the woodland and close proximity and connectivity to existing areas of ancient woodland recognised on the AWI, the woodland within the (proposed) site is considered likely to qualify as ancient woodland.’”
An Interim Ecological Impact Assessment (EcIA) carried out for Castlefort Homes states that a review of the archaeological assessment (ASE, 2020) revealed that the two east fields formed part of Great Wood on the site in 1622. However, by 1778-83 the woodland had been cleared from the two fields, leaving remnant strips of treelines. The remaining strips of woodland contain diverse broadleaved trees, but the ground flora is largely common, although does include few ancient woodland indicator species, with treeline strip T2 (on the southern edge of the Ridgewood Stream) being dominated by ramsons.
Had ‘Great Wood’ survived, it would now have been designated as Ancient Semi-Natural Woodland. Therefore, it must be assumed that these surviving strips should be similarly classified, especially as they include “a few ancient woodland indicator species”.
In addition, treeline strip T1 is the area identified in the PEA survey as the field boundary towards the eastern extent of the farm, i.e. “likely to qualify as Ancient Woodland”. The ground flora found in T1 by the EcIA surveyor were ramson and wood mellick, and in T2 ramson and pendulous sedge. From personal experience I know that in season, bluebells, wood anemones and early purple orchid (more ancient woodland indicator species) are also present in T1.
It is noted that both these treelines will be retained “under the current proposal” and the PEA survey states that “in respect to both the ancient woodland recognised on the AWI and the woodland within the Site which likely qualifies as ancient woodland, it is strongly recommended that no works associated with the proposed development be undertaken within a distance of less than 15m from the woodland edge”.
Bearing in mind that the developer’s proposal intends some of these treeline areas to be retained as natural dividers between different areas of the development, the presence of ancient woodland within the proposed site is a very material consideration in the planning process. The results of the EcIA survey downplay this aspect significantly.
Also of concern is the proposed installation of a footpath on the western side of Lewes Road adjacent to Ridgewood Place, which includes another strip of ancient woodland. Again, disturbance and damage here are inevitable owing to the work which would be required to protect both the tree roots and their aboveground growth. The available drawings show that a retaining wall would be required to support the footpath, but how that could be provided without damaging tree root structures is open to question.
The biodiversity value of ancient woodland and the importance of conserving it is outlined within the UK government’s vision that “ancient woodlands, veteran trees and other native woodlands are adequately protected, sustainably managed in a wider landscape context, and are providing a wide range of social, environmental and economic benefits to society”.
The presence of ancient woodland within the proposed Horstedpond Farm site is a material consideration in the planning process. The NPPF states that “planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and for 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”.
Furthermore, ancient woodlands are recognised for their local value to biodiversity, which is reflected in their inclusion within the Woodland Habitat Action Plan (HAP) for Sussex, in which one of its objectives is to “maintain the existing area of ancient semi-natural woodland”.
Horstedpond Farm Action Group (HFAG) objects to this planning application on the basis of the potential deterioration and detrimental impact it would have on Horstedpond Wood and Park Wood, two areas of Ancient Semi Natural Woodland designated on Natural England’s Ancient Woodland Inventory which are adjacent to the proposed site.
If the project was allowed to proceed, the developer would have to provide, as recommended by the Woodland Trust, a larger buffer zone of 50 metres to ensure that adequate protection is provided to these areas of ancient woodland adjacent to the proposed site boundary.
In addition, the two areas considered to qualify as ancient woodland should be afforded the same protection as designated parcels, and they should be assessed by a qualified, independent person recommended by one or more of the Woodland Trust, Natural England and the Forestry Commission.
Only 2.5% of the UK’s ancient woodland is left. What remains represents a valuable and irreplaceable habitat. Once damaged and lost due to ill-conceived and ill-planned housing developments, this woodland is gone forever. Any developer promoting a scheme that results in the loss or deterioration of ancient woodland must, at the very outset, consider all possible measures to ensure avoidance of adverse impacts.