WMP submissions

"Until the airport bought Marlhill Copse I didn't even know it was there - and I dearly wish that was still the case. My first walk through it showed me that there is more wildlife in this small area than anywhere else in Southampton, and I've walked all the greenways. The reason for that seems to be that the Copse has been left alone for decades and nature has done what she does best and generated renewal. The proposals the airport is making to remove trees and reduce the height of many more is an act of vandalism. This obsession with "tidying up" the Copse is solely aimed at reducing the height of the trees for commercial reasons, it seems to me. Suggesting that the copse will become a public open space with more people using it will also negatively affect the wellbeing of the wildlife which has flourished with few people going through. I strongly object to this proposal." [LB Bitterne Park]

Dear Councillor Steve Leggett,

I am emailing you to comment on the recent felling application for Marhill Copse. I comment first as a conservation scientist from the University of Southampton.

Designated as a Plantation on Ancient Woodland Site (PAWS), subcompartment 1 is irreplaceable. While PAWS sites do not currently afford legal protection in the UK, English policy prohibits developments that damage ancient woods “unless the benefits of the development… outweigh the loss”¹. The felling of woodland cannot be justified on these grounds, because no attempt has been made to measure the loss of the multitude of benefits that this woodland provides to wildlife and society. Ancient woodlands, including PAWS, are irreplaceable biodiversity resources due to the length of time is takes for wildlife communities to recover following clearfelling². Ancient woodlands also hold higher aesthetic appeal than younger woodland³. Many of the likely benefits are immeasurable, including their importance to residents’ health and wellbeing, and as a source of inspiration for local culture.

Just 2.4% of the UK is covered with ancient woodland. The UK government has committed to international agreements, such as the Helsinki Protocol, which encourages sustainable management of woodland, including ancient woodland, and the conservation of its biodiversity. The clearfelling of Marhill Copse’s PAWS is precisely at odds with this agreement.

Objecting to the destruction of Marhill Copse, and to the airport expansion provides an opportunity for the council to lead by example in responding to the declared climate emergency. EBC made a pledge when they declared a climate emergency: “To stay within the targets set out in the Paris Climate Change Agreement, Eastleigh Borough has a carbon dioxide (CO2) emissions budget of 3.8 million tonnes (MtCO2) that it can use between 2020 to 2100.”⁴. However, the climate impacts produced by Southampton Airport from the aircraft using the airport is estimated to be 998 thousand tons of CO2 equivalent in 2021 (this includes taxing, take off, landing, climbing, cruising, and descent). The total emissions for the Eastleigh area for 2021 (minus aviation) are projected to be 609 thousand tons of CO2 equivalent.

998,000+609,000 tonnes = 1,607,000 in 2021.

X 79 years (between 2021 and 2100) = 126,953,000 tonnes.

So, this exceeds the emissions budget of 3.8 M, as pledged in the declaration, by 33.41 times!

Secondly, I comment as a citizen. The airport extension will severely impact on Southampton residents’ health and wellbeing. I ask the council members the following. Do you actually live in the area that will be impacted by the airport? Do you visit Marhill Copse? Do you have relatives with asthma, who will suffer with the increase in air pollution? Can you live with the increase in premature deaths? Do your children attend local schools? Are you not concerned about their future, as their learning will be compromised by the noise? Are you not concerned about the climate crisis?

Regards,

References

1. Department for Communities and Local Government. National Planning Policy Framework. (2012).

2. Spake, R., Ezard, T. H. G., Martin, P. A., Newton, A. C. & Doncaster, C. P. A meta-analysis of functional group responses to forest recovery outside of the tropics. Conserv. Biol. 29, 1695–1703 (2015).

3. Gobster, P. H. Forest Aesthetics, Biodiversity, and the Perceived Appropriateness of Ecosystem Management Practices. Defin. Soc. Accept. Ecosyst. Manag. a Work. Proc. 77–97 (1996). doi:citeulike-article-id:2767922

4. Eastleigh Borough Council. Climate emergency: the facts for Eastleigh. Climate Change and environment (2020). Available at: https://www.eastleigh.gov.uk/climate-change-and-environment/climate-emergency-the-facts-for-eastleigh.

"The WMP is remarkably short on detail as to precisely which works are to be encompassed. How many trees to be felled (and which ones)? Which trees to be crown-reduced (and by how much)?

There appears very little difference between this WMP and the intention declared by SIAL (in March 2019) to reduce the height (including felling) of 219 trees (93 by more than 10 metres).

Page 4 para 1: “In August 2018, Southampton International Airport Ltd (SIAL) purchased

Marlhill Copse, Swaythling, in order to undertake tree management work required under European Aviation legislation. Specifically, the airport has an obligation to manage and minimise obstacles that breach a set of 3D safeguarded surfaces around the airfield.”

This just does not ‘stack up’:

Whilst acknowledging that tree height reduction for aviation purpose is the only reason the airport bought Marlhill Copse, this is misleading: European Aviation legislation (e.g. Commission regulation 139/2014) does not even mention ‘trees’. The legislation is concerned only with obstacles being avoided. This aircraft currently do this by adjusting their loads and take-off behaviour to avoid obstacles. In any case, EASA 139/2014 does not confer any greater powers than previous legislation. It is indeed legally arguable that the powers of the secretary of state to enforce obstacle removal are now no different than they were in 1947.
If the airport continues to argue (erroneously) that it has a duty to reduce the height of trees in order to comply with 2014 legislation, this means it must have been behaving illegally since 2014 if it has taken until 2020 to reduce the height/fell these trees.
The 3D surfaces referred to by the airport in 2019 appear to date from 2001 and have not therefore been modified by the European legislation from 2014.
If SIAL has a legal right to reduce the height of these trees, why attempt to do so by the backdoor in a WMP rather than just ‘do it’?

Section 1: “The information in this management plan & associated Inventory & Plan of Operations will be used to apply for a Felling Licence & conduct woodland improvement.” False. The Forestry Commission says “FC are no longer expected to approve the plan or see a felling license for this site.”

Section 2.1 is inappropriate and redundant as a ‘vision’; Marlhill Copse is already “a place of historical natural beauty with extraordinary biodiversity, and provides a safe, sustainable and accessible space which educates, inspires and is prized by the whole community.”

Section 2.2 (5): “Restore and improve derelict land.” Which land is ‘derelict’?; why is it regarded as ‘derelict’?; how is to be restored?

Section 2.2 (6): “Conserve heritage features.” Which features? What criteria are used to differentiate ‘conserve’ form ‘restore’ [2.2(5)]?

Section 2.2 (7): “Convert pine dominated southern and eastern edges to a natural shrub interface.” How and Why?

Section 4.1: “Though derelict and in great need of suitable care and management, this woodland remains impressive and locally renowned.” The term ‘derelict’ is pejorative and inappropriately applied to woodland. The impressive nature of this woodland is because it has been unmanaged for so long. Its renown will be lost with the type of care and management that this WMP proposes.

Section 4.2: The constitution and status of the proposed “Friends of Marlhill Copse Community

Woodland’ is not specified.

Which paths will be ‘permissive’ is not specified. No reference to the public right of way status of the route through is made.

Section 5.6: Why does reinstatement of the watercourse through the Copse (the ‘new river’) not from part of the WMP?

Section 5.9: “..an initial period of flight safety works..” How long is this initial period and what precise works would it comprise. See comments about page 4 para 1. At which point after the runway extension is built is it anticipated that these works would become ‘flight-safety related’? Which aircraft (and to which destinations) will be ‘flight-safety’ affected?

Section 5.10 “Climate Change Resilience” is just plain wrong. See SCC/UoS study (2017) saying Southampton needs more large old trees – the very type the WMP wants to remove.

Section 6.1 “Pollard or crown-reduce, not fell, the mature broadleaved trees that invade the flight safety zone from Southampton Airport and leave monoliths where possible.” No good ecological/biodiversity/forestry reasons are given. Plain destruction for the purposes of company share price. Such a statement has no place in a supposedly professional WMP.

Section 6.7 “Fell the mature pines and associated potentially unstable Mixed Broadleaf (MB) between the Driveway and southern boundary against the closely adjacent housing in the south and SCC field to the east.” Numbers of fellings, age, CAVAT (Capital Asset Value of Amenity Trees) and precise location are not given. ‘Unstable’ and ‘potential’ are not specified.

Section 6.8 How is the ‘independence’ of this group to be guaranteed?

Finally, no details are given about the process by which this WMP will be considered and by whom."

I am deeply concerned by the plan. I find in it evidence that it is quite simply a device for tree-height reduction. For example, in the section 4.1 titled "Description":

"A light crown thinning to best stems on an eight to ten-year rotation, concentrating on removing the young Sycamore & Norway Maple and older Turkey Oak content and reducing the crop height at the top of the hanger, whilst controlling the other invasive exotic species of Dwarf Bamboo, Skunk Cabbage, Japanese Knotweed and Himalayan Balsam, will have an immediate positive impact on biodiversity. Such height reduction will be achieved by judicious thinning and by crown reduction of the fine impressive mature old Oaks, London Plane and Common Lime so retaining them indefinitely for posterity."

I would firstly argue that this paragraph and the following paragraphs must go in the Management Strategy, not Description, so that these intentions are not overlooked by anyone turning straight to the strategy to understand what activities will be undertaken in the woodland.

In terms of "removing young Sycamore" - why has the airport recently planted Sycamore? These are contradictory, and further Sycamore is valuable for biodiversity http://insight.cumbria.ac.uk/id/eprint/624/1/Leslie_TheEcologyAndBiodiversity.pdf.

More significantly, the above paragraph includes the phrase "such height reduction" as if height reduction has previously been referred to in the document, which it has not. There is no biodiversity benefit to height reduction. In fact, the loss of structural complexity cause by removing naturally occurring features of mature trees (e.g. deadwood, cavities and tears) will dramatically reduce the available habitat for specialised fungi, plants and animals - i.e. reducing crowns will actively reduce biodiversity.

Additionally, the likely impact of crown reduction on the growth pattern of these trees may be that they grow higher (https://bsapubs.onlinelibrary.wiley.com/doi/pdf/10.2307/2656846) - which will result in a greater focus from the airport and more habitat disturbance as they continually 'manage' the tree heights, or more likely demand that they are felled.

Whilst, 'special character' is a subjective judgement, Southampton City Council should not leave this judgement of this to the airport. Part of this special character are the tall mature trees and the "pine dominated southern & eastern edges". You give no sound reason for objective 7: to convert these to "a natural shrub interface" and this conversion is unacceptable.

This woodland has been little disturbed for some decades and natural processes have been allowed to take over. Instead, the Woodland Management Plan, specifically objective 9, indicates that the area will be turned into yet another amenity woodland - with paths, benches and safe access. Southampton already has several of amenity woodlands. Instead, Marlhill Copse should be lightly managed to maintain and enhance the unique ancient and exotic 'wildwood' rather than to sanitise into a "safe and accessible community woodland".

I do agree that the management and removal of invasive species - such Rhododendron ponticum, Himalayan Balsam - is necessary. However, the "removal of trees that are dead or dangerous, trees that are of poor physiological condition, trees that are of poor physical form and competing trees" is contrary to good forestry practise in this wild landscape. In particular, the claims of the assessment appeal to safety concerns of the Council without observing that dead wood, fungal growth and falling limbs are necessary to the healthy functioning of complex woodland habitat and to remove these features will dramatically reduce character and diversity of this woodland.

On the specific concern of public safety, 'often the dangers of trees are considerably overestimated' https://naturenet.net/blogs/2007/02/19/killed-by-a-falling-tree-what-are-the-chances/ and the chances of being hit by a falling tree are miniscule - considerably less than the risks on the city's roads that residents accept on a daily basis. Visitors to the city's other woodlands accept that branches and trees will fall from time to time, and visitors to Marlhill will accept the same. Marlhill Copse does not need to be sanitised or made "safe for the public".

Your plan states you have 8 key objectives and I will set out why your plan fails on each and every one:

- Enhance and maintain habitat diversity

Your plan directly contributes to reduction of habitat diversity. Trees outside of commercial growth do not have a 'useful life expectancy'. Alive and dead they provide a hugely important habitat for a wide variety of wildlife. Removing larger trees simply denigrates the environment, lessens diversity and reduces the amenity value of the land for local residents.

Trees drop limbs and fall in high winds. This is evident from the effects of the recent years storms in all of Southampton Parks. If fallen trees and dropped limbs do not pose a high risk in parks why do they do so in a largely wild area? You cannot stop the processes of nature. If you are concerned about your liability place a sign at the entrance warning people not to enter during periods of high wind or sell the land to community or the Woodland Trust as have previously been suggested. If you consider it poses such a high risk you should not have purchased it in the first place.

- Promote sustainable woodland management & regeneration

Woodlands are a natural resource, with no management the area has proved to be self sustaining and does not require regeneration. Making something open & 'pretty' with play areas for children does not make it sustainable. The woodland is surrounded by managed parks which provide plenty of play areas. Leave this for the wildlife we so desperately need.

- Embrace the woodland’s landscape contribution

We, as local residents, do embrace a wild area in the middle of a city. You simply wish to turn it into a managed playground that does not interfere with you expansion plans. By flying larger or more laden planes out of the airport you will destroy the contribution of Marlhill Copse for economic gain of your shareholders.

- Remove and control invasive exotic species

The exotic species are part of the area's history. Marhill copse was part of a large estate and the species are not escaping or overwhelming the natural environment.

- Restore and improve derelict land

The pejorative use of the word 'derelict' simply proves your efforts are not in the interests of wildlife. Derelict land could equally be described as 'returning to nature', 'rewilded' or even 'nature'.

- Conserve heritage features

Wrought iron fencing and tarmac is not a 'heritage feature;

- Convert pine dominated southern & eastern edges to a natural shrub

Interface

Again the pejorative use of phrasing suggests there is something wrong with pine. The beautiful, mature tree that form habitat for many wild animals do not need to be replaced with shrubs. There are large areas of shrubs and small trees towards the bottom of the hill and this again suggests your interest is finding any excuse for removing tall trees that interfere with expansion plans for the airport rather than any interest in biodiversity.

- Adopt a safe and accessible community woodland ethos

You have no interest in accessibility of this area of woodland. Since taking over management you have failed to maintain accessibility through the area closest to Cutbush Lane. The path is almost fully overgrown and you have made no effort to increase the real accessibility of this area.

In summary I have no idea why a commercial airport would purchase an area of woodland other than for commercial reasons. If you had no motive that benefits the commercial airport you would not have done so and to suggest otherwise is to treat the local community as fools.

There is no mention of the Monterey Pines in this Woodland Management Plan! This is utterly remiss when these are clearly part of the defining character of this woodland. This must be rectified. Specifically, this should name the pines as Monterey Pines, state that they form the character of the Southern and Eastern edges and give the rough date of planting (end 19th to beginning 20th century).

I quote the following from your WMP.

P. 5. SIAL are fully committed to their health and safety and community

responsibilities as current owners of the copse. However, in the long term

SIAL’s mission is to find the most appropriate owners for Marlhill Copse. During

the delivery of this woodland management plan, an independent group will be

set up to assess options for future ownership and agree a plan for handover

and ongoing management. The group will be responsible for identifying the

most suitable future owner and ownership model to ensure the ongoing and

future restoration and enhancement of the woodland for all to enjoy. '

I do not trust the motives behind this WMP. The Airport purchased the copse in 2018. Why? If works needed to be completed for aviation safety then the existing owners would have been obliged to undertake these works. If they were unable or unwilling and the only option was for SAA to purchase the copse, then it would be more open and transparent to say so.

Why buy the copse to then, as per the above quote from the WMP, 'identify a suitable future owner'. Why not keep the copse and retain responsibility over it? Why pass the costs on to someone else?

Is it that you will have used it for your purposes i.e. to lower the height of all trees that would prevent the flight path of larger planes out of the Airport in line with your application for expansion?

There is an underlying sense of unease when reading the WMP.

If your purchase of the copse is a purely altruistic gesture and not a hard nosed business move, then you could agree to leave the tall trees in the copse that do not interfere with your current flight paths, improve and manage the woodland as you suggest and retain the cost of future management within your budget. That way perhaps the public might believe that this is not a smokescreen for airport expansion.

Having read the woodland management plan, I found that some areas of the plan either made little sense or lacked clarity. The problems I identified are as follows:

Section 2.1 – Vision

The woodland management plan states that they have a long-term vision for Marlhill Copse but what it does not state is why it isn’t already “a place of historical beauty with extraordinary biodiversity”. What is the copse currently lacking in Southampton Airport’s view?

The images of what the copse may look like in the future - https://www.southamptonairport.com/about-us/aerodrome-safeguarding/marlhill-copse/

The images seem to suggest that there will be a play area of some description for children but there is no mention of that in the plan at all. If there is a view to encouraging children to play in this area, the plan needs to have a section to explain how it will manage the problems created by increased footfall such as litter and the inevitable damage to the vegetation.

Sections 2.2, 6 and 8

The problem with these sections is Southampton Airport’s claims which are unsupported by evidence or even an explanation. For example, the woodland management plan refers to derelict land but it does not explain where in the copse it is or what non-biodegradable refuse is there. The term derelict is mentioned again in section 4.1 without justifying why it is so. The only conclusion that can be drawn by the use of this term is that Southampton Airport is trying to present a problem with the woodland that needs fixing. What it does not do is tell us what the problem actually is or the area that it affects.

On a similar note, it also mentions heritage features but fails to define why fencing and tar-bound surfaces are classified as such. This appears to be an attempt by Southampton Airport to legitimise the woodland management plan and make it ‘sound good on paper’ without actually having any substance.

Another point of concern is the conversion of the pine dominated southern and eastern edges to a natural shrub interface. The plan again seems to suggest that mature pine trees are somehow a problem without explain why. It also fails to explain why low-profile shrubby woodland edges is more preferable. A joint study carried out by University of Southampton and Southampton City Council in 2017 called “Understanding the value of Southampton’s urban trees” clearly state that Southampton needs more large, old trees which is exactly what these mature pine trees are. To permit the replacement of these trees with low-profile shrubs clearly contradicts the finding of this report.

Section 5.9 and section 6

The point which causes the most concern is the mention of flight safety works within the woodland management plan. The plan mentions an initial period of flight safety works plus remaining activity to be phased in over several years but again the plan is very thin on details. How long is this initial period and what remaining activity will need to be carried out over the coming years? How will this be balanced against all the other objectives such as adopting “a safe and accessible community woodland ethos”? To put it specifically, how can years and years of ongoing work be reconciled with prioritising public safety, encouraging access to and use of the copse to establish initiatives and events within the copse to focus on education, community engagement and sustainable management?

The plan’s emphasis on the need to thin and crown-reduce trees despite not providing an explanation as to why these steps are necessary leads only to one conclusion. That the whole plan is geared towards facilitating the expansion of Southampton Airport. Since purchasing Marlhill Copse, Southampton Airport have declared that they will be reducing the height of 219 trees and this plan appears to be an attempt to proceed with that declaration.

Southampton Airport have attempted to argue that they are obliged by European Aviation legislation to reduce the height of the trees. But if that was the case, they will also need to explain why it has taken them six years since the introduction of the legislation to comply with it. Again, this argument appears to be an attempt to mislead the community into supporting their plans to fell the trees which would in turn pave the way for the airport expansion to take place.

Whilst the woodland management plan appears to have the interests of the community at heart, we must also remember that Southampton Airport is not a charity but a commercial business whose aim is to generate profit for its shareholders. As such, the woodland management plan must have some sort of commercial benefit for the business. Perhaps Southampton Airport would like to elaborate on what that might be.

The tall trees at Marlhill Copse do not breach the 3D safeguarded surfaces for current airport operations, but would do so for an extended runway with larger planes. The Copse has been purchased by SIAL to facilitate airport expansion, which is the driver for the proposed Woodland Management Plan. I oppose the proposed WMP, particularly the felling of tall trees and canopy reduction plan and I oppose the expansion of Southampton Airport.

This statement from the WMP identifies the primary motivation for the plan:

"Pollard or crown-reduce, not fell, the mature broadleaved trees that invade the flight safety zone from Southampton Airport and leave monoliths where possible."

A large segment of the copse is classified as ancient woodland, containing roughly a third of the trees targeted for crown reduction in the WMP. I can see little justification on H&S nor biodiversity grounds for these canopy reduction works. Branches will fall (we tolerate this risk elsewhere), mature trees eventually die back and woodland will regenerate naturally without the need to reduce the crown of mature trees. The great storm of 1987 showed us that woodland regenerates best when left well alone by the Forestry Commission. Elderly/veteran trees support biodiversity long after their canopies have died back. Indeed the Forestry Commission's good practice guidance on managing ancient woodland includes as a management success criterion: "Veteran trees and deadwood: Existing veteran trees have been identified and are being protected, and future replacement veterans are being conserved. The amount of standing and fallen deadwood is increasing". Further, it states that any canopy reduction that might be required to reduce competition to veteran trees is a risky business: "When reducing canopy competition around veteran trees in dense stands, the sudden exposure to wind and sun can stress the tree, damage lichens and mosses living on it and increase the risk of windblow. Consequently thinning around veteran trees should be selective with progressive, gradual reduction of the surrounding canopy". Importantly, the canopy reduction proposed in the WMP is not to protect mature trees from competition, but to remove obstacles to airport expansion - I believe this to be unjustifiable.

Yes, woodlands benefit from active management to maintain biodiversity, but the last organisation I would wish to manage Marlhill Copse for biodiversity would be SIAL or its contractors - airports and larger wildlife (esp. birds) make uneasy companions.