2. The draft strategy sets out some key principles. To what extent do you agree or disagree these are the right principles?

Protecting existing trees and woodlands

Expanding trees and woodlands in both rural and urban areas

Enabling nature recovery

Involving everyone in our vision for trees and woodlands

Why? Are there any other principles you think should be included?

There are some important additions and amendments that we feel need to be made to the ‘protecting existing trees and woodlands’ principle. There is mention throughout the draft strategy of ancient woodland being an ‘irreplaceable habitat’ and rightly so, due to the complex networks of fungi that develop in undisturbed soil through centuries of decaying plant matter. If CCC wants to be truly forward-thinking and ambitious in their woodland strategy, they should commit not only to no loss of ancient woodland whatsoever but a principle that no development will be approved in, adjacent to or near to ancient woodland. A study commissioned by the Woodland Trust in 2008 highlights a wide range of damaging impacts that development at close proximity to ancient woodland can cause to these special habitats. Yet recent developments such as that in Cockering Farm, Thanington, and proposed ones such as R1 in the CCC Draft Local Plan, are worrying given their scale in relation to the woodlands and their proximity to these ecosystems.       

Furthermore, recognising how long biodiverse woodland habitats take to establish, CCC should move away from the language of ‘net loss’. Planting more trees to replace an existing woodland should never be a justification for allowing development, as new trees/woodlands will never adequately replace an existing complex ecosystem.

We would recommend including ‘integrated woodland management’ into these principles. Part 2 of this draft strategy highlights the importance of good management and Part 3 the dangers of woodland lotting, which is leading to a rise in ownership of small parcels of larger woodlands without any overarching management strategy. We suggest one possible tactic later in our comments re: facilitating forums for local wood stakeholders.

We would also recommend including ‘active monitoring’ within these principles. In particular, surely CCC could play a role in ensuring that legally responsible bodies (such as Natural England for SSSIs) undertake inspections/operations within an appropriate timeframe. For example, Natural England are supposed to inspect SSSIs every 6 years, yet recent evidence across the UK suggests this is only achieved in half of SSSIs (some parts of Adisham’s SSSI haven’t been inspected since 2008). As we suggest later in our comments, including representatives from these organisations in local forums with owners, community groups/reps and policymakers could help here.

Lastly, under the ‘involving everyone’ principle, it would be good to see commitment to working alongside KCC to maintain safe and responsible PROW access and monitoring misuse of these PROWs; maintaining access while preventing damage to habitats.

Part 2: About Canterbury’s Trees and Woodlands

This section of the draft strategy gives details of:

- current tree canopy cover across the district
- ancient, veteran and noble trees
- the amount and location of woodland across the district
- access to woodland
- hedgerow areas

3. Do you have any comments on this section of the draft strategy? Do you think any changes should be made and if so, what and why? Please write in below

It would be helpful to see evidence here that CCC understands recent trends in woodland ownership, including the rise of woodland lotting companies buying large areas of woodland, splitting them up into small parcels and selling them on at much higher prices per acre. This growth in woodland lotting is fragmenting the management of woodlands that in many cases have been traditionally managed as a whole, which has consequences for management practices such as coppicing regimes and PROW maintenance. The concerning impacts of this trend in Kent were outlined in a 2007 report created with support and funding from the European Regional Development Fund, Kent Downs AONB, Forestry Commission, KCC and Natural England.

As well as the proposal of planting trees to integrate currently fragmented woodlands, which is a sound strategy, CCC should consider what possibilities there are for restoring formerly wooded areas. As we mention later in our comments, areas such as Woolage Green saw large and extensive areas of woodland ravaged in previous decades/centuries by agriculturalists. In some cases, like Woolage Green, these areas are now low-grade farmland whose soil would likely still retain some important characteristics for successful woodland restoration.                   

We otherwise concur with everything set out in this section, which accurately describes the situation across the district with respect to woodland and trees.

Part 3: Trees and Woodlands for the Future

This section of the draft strategy sets out:

- our ambitions for the future
- how we plan to protect existing trees and woodlands
- why we need to expand tree cover
- how trees can mitigate the effects of climate change
- how and where tree cover can be extended

4. Do you have any comments on this section of the draft strategy? Do you think any changes should be made and if so, what and why? Please write in below

In the ‘Protecting Existing Trees’ section, there is no mention of Article 4 Directions and their potential as a tool for protecting woodland, particularly from development. Given the rising trend in small woodland ownership, particularly for leisure purposes, Article 4 Directions are able to prevent damaging operations that would otherwise fall within the scope of ‘permitted development’. There are examples around the country where these mechanisms have successfully protected woodland. We would urge CCC to strongly consider greater use of these powers in woodland contexts in the future, to prevent incidents such as the extensive construction of buildings and roadways seen recently in the ancient woodland in Adisham.

The mention of felling licences under Delivering Principle 1 should specifically highlight that no more than 5 cubic metres of timber should be felled per calendar quarter without a felling licence. It could also be mentioned that Defra and the Forestry Commission now have the power to impose unlimited fines on landowners who fell trees without a licence.

For Delivering Principle 2 on expanding woodland cover, the strategy could include a commitment to research previously wooded areas using historical material. The soil in many historically wooded areas will retain the qualities needed for healthy woodland establishment and will often link fragmented remnants of these former woods.

For Delivering Principle 4, we believe CCC can do more than simply providing information on species, natural regeneration and so on. There is an opportunity for CCC to take a leading role in bringing together responsible bodies (Natural England officers, Forestry Commission, Woodland Trust etc.), woodland owners, community groups and individuals such as Tree Wardens through hosting regular local woodland summits. These would allow sharing of up-to-date information between stakeholders (rather than general guidance), collective future planning, opportunities for integrated woodland management, greater oversight over operations by responsible bodies and greater community involvement in contributing to the future of local woods.

Overall, there are lots of positive ambitions and ideas here, however CCC should aim for more direct and specific strategies than just providing information.  

Part 4: Action Plan

The action plan sets out what needs to be done to deliver the draft strategy, who will lead on each action and when we aim to deliver each action.

5. Do you have any comments on the action plan? Are there any other actions you think should be included?

Re: funding sources, CCC must ensure that these are responsible, so that the council’s actions are not justifying ecological damage elsewhere (within or outside the district). Mention of s106 and Biodiversity Net Gain is worrying, as these concepts have previously been used to support developments that are highly destructive to important established habitats. For example, these principles featured in the planning application for the proposed development at Betteshanger Country Park in Dover district, which contains exceptional and nationally-rare biodiversity. Protecting these existing important habitats needs to be the priority and CCC must ensure it does not conspire in events that would damage these. It should therefore assess funding sources responsibly, keeping the fallibility and abstracted nature of concepts like ‘biodiversity net gain’ in mind.

For similar reasons to the above, we believe that CCC should avoid the language and paradigm of ‘net loss’ when making strategic decisions in relation to woodland, given the significance of established woodland habitats for ecosystem health and biodiversity in comparison to newly-planted trees.

6. Do you have any comments on any of the proposed areas for tree expansion as shown on the map on page 23 of the Tree Strategy?

We believe a further strategic area for tree expansion could be identified in Woolage Green, in the far south-east of the district. If you look at historical maps from the late 19th and mid-20th centuries, you’ll see a very large area of woodland (‘Woolwich Wood’) lying to the west of the settlement, which was formerly central to the identity of that parish and an important part of Woolage Green’s character as a place. This all changed in the 1960s when it was felled to make way for agricultural land. The farmland currently there in its place is now classified as Grade 3. Given its proximity to existing woodland and the context of the land being woodland in the not-too-distant past, this may even be an appropriate site for natural regeneration. However, this will need to be assessed further and the local community consulted in advance.

7. Do you have any other comments on the draft Tree and Woodland Strategy? If so, please write in below or alternatively you can upload up to three supporting documents if you would prefer

CCC should not underestimate the impact that new developments would have on woodland health. It is an admirable goal to intend to build ecological connectivity and access to nature/open spaces into policies for future development. But particularly for large residential and commercial developments, the combination of big increases in local population/traffic through areas, significantly greater artificial light and noise and the spread of non-native species (via garden plants and pets) will regardless always pose arguably the most significant threat to the health of local woodland (see again the aforementioned 2008 study by the Woodland Trust). This threat should be acknowledged.

Overall, we would urge CCC to ensure it takes a holistic approach to woodland that always incorporates the wider range of species that depend on trees and not just trees themselves, given these species’ crucial importance for biodiversity, ecosystem sustainability and pollinator health. CCC must ensure it does not abstract the other important components of these ecosystems out of the equation by focusing too much on measures such as carbon sequestration, canopy cover, biodiversity net gain and so on.

We would urge CCC to continue its positive and productive communication with local woodland and nature-focused community groups such as Watch Over Adisham’s Woods. It is encouraging to see lots of mention of community groups, tree wardens and other volunteers throughout this draft strategy. We hope CCC will maintain and enhance these important lines of communication into the future. It is often community members who know their local woodlands best and their knowledge should be valued and incorporated into future strategies.