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NPPF – beyond the celebrations

We are still over the moon that England's ancient woodland and ancient and veteran trees got the wholly exceptional protection they deserve, but the NPPF must be read as a whole. So now it is time to delve a little deeper into the changes and what they mean for our woods and trees.

The NPPF is even more focused on housing delivery. Launching it, the Secretary of State for Housing, Communities and Local Government, James Brokenshire, reiterated the Government’s aim to build 300,000 new homes a year by the mid-2020s. The new housing delivery test puts the emphasis on the number of houses delivered rather than the number of homes planned. If local planning authorities (LPAs) do not deliver this there is a threat that their plan will be deemed unsound and the ‘presumption in favour of sustainable development’ set out in the NPPF is applied a big stick which will make it increasingly difficult for LPAs to refuse housing development. 

Ancient woodland, ancient and veteran trees 

The ancient woodland protection given by the revised NPPF although much stronger is still caveated: development should be refused unless there are ‘wholly exceptional’ reasons. But what are these wholly exceptional reasons? A footnote gives the example of infrastructure projects, specifically mentioning hybrid bills, a clear nod to HS2. It also says the public benefit should clearly outweigh the loss. The definition of both ‘public benefit’ and ‘infrastructure projects’ both instantly throw up clear areas of contention which will certainly be tested in the courts. We shall be arguing strongly that this must be considered at a national scale localised benefits must not be deemed ‘wholly exceptional reasons’. Nonetheless we expect to see a dramatic reduction in the types of everyday applications that form our 'Woods under threat’ caseload and look forward to working with local authorities to ensure effective implementation. 

High quality design 

The Government has trumpeted that the NPPF will promote high quality design and make it easier for LPAs to refuse poor quality development. On the face of it the NPPF contains more warm words on encouraging early community engagement on design and expectations, i.e. they should be maintained rather than standards be allowed to slip as the planning process evolves. However, it remains to be seen how this emphasis on design will tally with the renewed emphasis on the delivery of housing numbers. This does little to empower LPAs when the risk associated with not delivering housing numbers is higher than the risk of not delivering good design. 

Likewise we are disappointed that the role of woods and trees in design has not been expanded beyond simply considering it as ‘landscaping’. The importance of urban trees was recognised in the 25 Year Environment Plan so it is especially frustrating that the NPPF did not reflect this. As the climate changes, the importance of putting woods and trees at the heart of new developments is becoming increasingly clear. That is why we especially heartened by moves from Wycombe council recently to require 25% tree cover in new developments and will be watching closely as this proposal is tested at examination.

New development in Bury St Edmunds (Image: WTML / Victoria Bankes Price)
New development in Bury St Edmunds (Image: WTML / Victoria Bankes Price)

Non ancient woods and trees 

For the first time the NPPF recognises the importance of non-ancient woods and trees and their contribution in terms of character and their natural capital and ecosystem services benefits. This is a great addition and one that we hope will help protect valued woods and trees, recognising the value they add to new development. It also links in with the Government’s 25 year plan for the environment and may give a hint of what is to come in the future with regard to offsetting and how we value our environment – definitely one to watch!  

Other issues 

We were really pleased to see that the lobbying from the Town and Country Planning Association paid off and the Garden City Principles were reinstated following their disappearance from the draft in March. This is critical to the emergence of garden towns and cities across England, without these principles they are just new towns, the principles instil a green and social heart to them. 

Likewise it was great to see that the hard work of the Wildlife Trusts paid off with the reinstatement of Local Wildlife Sites in the NPPF.  While the reinstatement didn’t go quite as far as it should have it was a definite improvement on the March draft which entirely omitted these important sites. 

Protection of the Green Belt remains unchanged, the new NPPF simply formalises the existing approach by adding in a test that ‘it has examined fully all other reasonable options’ before Green Belt sites are allocated. Thus essentially formalising the status quo. It is great to see the recognition that the National Forest and Community Forests are cited as offering opportunities for environmental improvements in the Green Belt. We hope that this policy will prove to be a positive tool in furthering the development of the Northern Forest.  

Full weight of changes

The full weight of the changes will not be felt until they are tested. We will be watching carefully and continue to fight for the best outcomes for woods and trees with a freshly strengthened platform when it comes to ancient woodland, ancient and veteran trees. Additionally, the emerging guidance supporting these policy changes will be critical. As we move towards a new Environment Act and a post Brexit land use policy world we will keep up the pressure to ensure planning delivers the best possible outcomes for woods and trees.  

We can only protect the ancient and veteran trees we know about

Tell us where they are with the ancient tree inventory