Tree Strategy Review 2010 - St Albans City and District strategy and policy for St Albans 2010 review 2 ST ALBANS TREE STRATEGY REVIEW 2010 INTRODUCTION The first Tree Strategy for

Tree strategy and policy for St Albans 2010 review

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CONTENTS Page

1. INTRODUCTION

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2. THE IMPORTANCE OF TREES

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3. TREES IN ST ALBANS DISTRICT

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4. TREES IN THE COMMUNITY

Tree warden scheme

Traditional orchards

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5. CURRENT CHALLENGES AND OPPORTUNITIES

Climate change

Common complaints

Green infrastructure planning

Sustainability

Development

Pests & diseases

Budgets

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6. LEGISLATION UPDATE

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7. POLICIES

All council trees

Street trees

Woodlands and wooded commons

Parks, open spaces and railway trails

Closed churchyards and cemeteries

Council housing trees

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8. TREES ON PRIVATE LAND

Statutory protection

Statutory protection of hedgerows

Trees on development sites

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9.

ACTION PLAN

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APPENDICES

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1 Related Documents 32 2 Glossary of terms 33 3 Trees and archaeological sites 35


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ST ALBANS TREE STRATEGY REVIEW 2010

INTRODUCTION

The first Tree Strategy for St Albans City and District was published in 2004. Since that time there have been a number of changes in legislation and national planning policy that impact on the management and protection of trees. Challenges such as climate change and sustainability considerations have also moved to the fore and the role that trees can play in addressing these challenges is becoming more widely understood. This review document includes updated policies and an action plan that will guide the management of publicly owned trees to promote a healthy and valued natural resource for the future. The Tree Strategy supports the District’s Sustainable Community Strategy priorities:

• Ensuring the District is a great place to be

• Supporting an active community that has pride in itself and cares for its future

It supports the delivery of the Council’s vision and particularly its priority:

• Delivering the District Vision to address future challenges and ensure sustainability

But it also supports other Council priorities including work on: Improving the streetscene and public realm. Making the District even greener and more attractive. Extending sustainability. Reducing the District’s carbon footprint. The aim of the Tree Strategy is to :

“Ensure that the trees and woodlands within the District are adequately protected, cared for and supported by new planting so that their extent, quality, biological diversity and contribution to the character and appearance of the District can be sustained and enriched for the benefit and enjoyment of the residents and visitors to St Albans.”

The next review of the Strategy will be due in 2015. THE IMPORTANCE OF TREES

Trees are essential to life. Their value cannot be overstated and they have an impact on many aspects of our lives. As they grow they: -

• Contribute immeasurably on a landscape scale or individually in urban and rural settings, contributing to people’s quality of life and sense of well-being.

• Release oxygen for us to breathe.


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• Absorb carbon dioxide (thereby reducing the greenhouse effect and helping to maintain a balance).

• Filter air and reduce other pollutants such as ozone, nitrogen oxides and sulphur dioxides, carbon monoxide, smoke, dust, ash and noise

• Support biodiversity

• Provide varied habitats for wildlife, both individually and as groups

• Provide a renewable resource of timber, fruit, seeds, nuts and fuel

• Create aesthetic value improving the appearance of our environment, giving variety of scale, form, colour and shape

• Reduce wind speeds giving shelter and comfort

• Reduce noise levels

• Reduce flash flooding and form an integral part of the natural water cycle

• Help ameliorate and mitigate against climate change

• Reduce everyday stress, particularly important in today’s environment

• Research has shown that there are health benefits of being able to enjoy the view of trees

• Provide shade from the sun and make areas more attractive to live and work

• Mitigate urban heat island effects

• Positively affect property values and help to attract investment Maintaining a healthy tree population is fundamental to maintaining a healthy environment, as trees play a vital role in mitigating against climate change and promote biodiversity and the establishment of sustainable communities. Trees are also central to landscape quality and contribute greatly to the amenity of an area as well as providing food and fuel. The District’s trees provide a healthy green infrastructure are therefore a key factor in the successful implementation of the District Vision and other Council priorities, and the Sustainable Community Strategy. TREES IN ST ALBANS DISTRICT The District has a varied tree population whose age and character largely reflects that of the built landscape around them. Trees are an important feature in the landscape throughout the District, even in the urban centres. Council Policies for public and privately owned trees are set out in pages 10-15 of this document. Most of the southern part of the District lies in the Watling Chase Community Forest (see map). The forest was established in 1995 with the objectives of increasing tree cover and improving public access (see the Watling Chase Plan Review 2001). The area has a high concentration of mineral workings, both active and restored, and this factor has presented barriers to the achievement of the forest aims so far. Watling Chase is currently being

Shade pools in St Peters Street


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TREES IN THE COMMUNITY St.Albans District Council Voluntary Tree Warden Scheme

In 2007 St.Albans City and District Council launched its voluntary Tree Warden Scheme, working in partnership with the Hertfordshire Countryside Management Service, The Tree Council, Parish Councils and Residents Associations. The Tree Warden Network is part of The Tree Council's UK-wide Tree Warden Scheme, which is run in partnership with National Grid and backed by the Department for Communities and Local Government.. The Tree Council launched the Tree Warden Scheme in 1990 as a national force of volunteers dedicated to their communities' trees - in town, city or countryside. It has co-ordinated it ever since, working with local authorities, voluntary organisations, parish councils and local partnerships to develop Tree Warden networks. Today there are Tree Wardens in communities throughout the UK. Tree Wardens are involved with a range of activities, including gathering information about their local trees such and reporting on storm damage or vandalism. They also get involved in practical projects such as planting and caring for trees in their local community and encouraging others to value their local trees and woods. A recent initiative for tree wardens has been special trees within the district.

St Albans City and District currently has 43 Tree Wardens and successful projects so far have included several community hedge planting schemes funded through the Tree Council. Anyone interested in becoming a Tree Warden should contact the Council’s Trees and Woodlands section. Traditional Orchards Traditional orchards are a much loved part of our British heritage and countryside and support a wide range of wildlife due to the mosaic of habitats they encompass including fruit trees, standing and fallen dead wood, scrub and hedgerows. Surveys have shown that orchards provide a refuge for over 1800 species spanning the plant, fungi and animal kingdoms. The noble chafer (Gnorimus nobilis), one of our rarest beetles, is associated with old orchards where it is dependent on old decaying wood within live trees especially apple, plum and cherry. Often occupying the same piece of land for centuries and managed without any chemical input, these sites were hotspots for biodiversity, but they are now under serious threat. It is for this reason that the U.K. Biodiversity Action Plan (BAP) now includes Traditional Orchards. Historical data shows that the orchard area across England has declined by over 56% since 1950. In Hertfordshire initial indicators show a decline of 58% in the number of orchard sites in the county over the past 100 years with most of the surviving orchards being in relatively poor condition. Many of these orchards would have contained fruit varieties local to Hertfordshire with the result that many local varieties of fruit may have been lost. The Hertfordshire Orchard Initiative (HOI) was established in 1998 in response to the rapid decline of Hertfordshire’s orchards and fruit heritage. It is run by a group of Local Government Officers, orchard owners and wildlife experts to enable and support the conservation and management of Hertfordshire’s fruit orchards and cultivars and promote healthy eating. (for further information visit www.hertfordshireorchardinitiative.org.uk) Current concerns in relation to food security and promoting sustainable communities have stimulated a surge in Grow Your Own activities and community food projects. There are a


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number of community orchard projects in the District, the largest of which will form part of Heartwood Forest. CURRENT CHALLENGES AND OPPORTUNITIES Climate change Climate change is one of the most serious environmental challenges facing us in the 21st century, both globally and locally. Back in 2006, St Albans City and District Council signed the Nottingham Declaration on Climate Change, a voluntary pledge to implement a plan of action to reduce both its own, and the wider community greenhouse gas emissions. Within this plan the Council set itself a target to reduce CO2 emission by 3% every year from the 2006 level to achieve 60% reduction by 2025.

As well as reducing our emissions, we also need to ensure that we are prepared for the climatic changes which are already underway. Because of the way climate systems work, we are locked in to a change in climate for the next 30 years that is influenced by our past emissions. Trees have an important part to play in mitigating for the effects of climate change, both in urban and rural areas. The Council is therefore aiming to increase tree cover in the District and new developments will be expected to allow appropriate space for the planting of shade trees. Climate change presents challenges for humans in many areas of life and technology is advancing all the time to help us. Our flora and fauna is also being challenged and will need to adapt, move to or colonise more favourable conditions if they are to survive. The choice of species used for new planting will have to reflect what will survive in a changing climate. This may extend to using trees with a lower water demand in the event this becomes necessary to reduce the number of subsidence cases although at the moment these are relatively rare. One of the potential side effects of climate change is an increase in the number of storms. This can lead to people living near large trees becoming concerned about their safety. These fears are mostly unfounded, and can at least in part be addressed by regular inspections of trees and remedial works if they are found necessary. Many of the valuable wildlife habitats in the District are fragmented and isolated and it is critical that wherever possible links are restored and that useful networks of wildlife corridors are established to facilitate adaptation. Trees are an important component of wildlife corridors, providing food and shelter for a wide range of species. It is possible that certain species of trees will not be viable in the District as climate conditions change and this needs to be borne in mind in future planting schemes. Green infrastructure planning seeks to address these issues. Common complaints about trees.

Light Although shade from trees is regarded as a benefit, it can also lead to complaints about blocked daylight. Although there are some cases where tree work is needed because of trees causing an excessive impact upon daylight, many complaints are found to be unjustified. Crown reduction or lopping to reduce shade by trees can be harmful to tree health and can leave them disfigured unless they have been regularly managed in this way. Otherwise such works are therefore only considered as a last resort as is the complete removal of any tree because of obstructed daylight. Property owners have a


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common law right to cut back overhanging growth from trees as far as their boundary unless the tree is protected by a Tree Preservation Order or Conservation Area. Falling leaves and other debris Trees drop leaves as part of their natural lifecycle, and they also shed debris from flowers as well as fruit, the latter of which can be light airborne seeds or larger fleshy fruits depending on species. Although inconvenience can result from leaves or fruit, this is mostly a temporary problem linked to the seasons. Highway paved areas badly affected by leaves or fruit can be cleared by the council’s street cleansing teams. Structural damage to buildings Trees can cause damage to light structures such as boundary walls through direct root action. They can in rare cases contribute to subsidence in buildings, although this requires a shrinkable soil to be present. Detailed investigations (usually by the claimant’s insurer) are needed to demonstrate a link to trees before considering action. Blocked drains Tree roots generally gain access into drains if there is a leak. In many cases, drains are set deeper than average rooting depth of trees. The number of cases of root blocked drains is therefore relatively low. Safety of trees Trees can fail through damage by a number of causes including storms, decay fungi or loss of root anchorage. As they are living things, trees cannot be guaranteed to be safe, but providing trees in areas used more frequently by the public are inspected on a regular basis in order to identify any obvious defects, any potential risk can be reduced to an acceptable level. A disproportionate response to safety concerns leading to heavy lopping or felling of trees would cause unnecessary harm to the landscape and environment as a whole. Poor television reception Terrestrial television signals can still be received by homes in spite of trees being nearby. Satellite signals are however far more sensitive to nearby trees, and more complaints have been received due to the increased subscription to this service. Tree work requests have historically been refused due to the potential harm they would cause to the tree population and the overriding benefits they bring. Green Infrastructure planning As trees are important features in the landscape, are living organisms that promote biodiversity and are also part of the water and carbon cycles in our environment, they are a key component of successful green infrastructure. The Council is working towards the preparation of a Green Infrastructure Plan which will identify and seek to protect, extend and enhance existing green infrastructure networks in order to facilitate the adaptation of plants and wildlife to climate change and provide a quality environment for residents and visitors. It is essential that adequate space is allowed in new developments for appropriate tree planting if these objectives are to be met.


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Sustainability Trees represent a valuable renewable natural resource and the management of the Council’s tree stock will seek to implement sustainable solutions in line with current government guidelines and best practice. Trees can also play an important part in Sustainable Urban Drainage Systems (SUDS), by reducing runoff and uptake of water. Guidance and information is awaited on the implementation of the Flood and Water Management Act 2010 which requires new developments to include provision for sustainable drainage. Development The District is currently under significant pressure from development and it is anticipated that this will continue into the foreseeable future. Trees are long lived organisms that take many years to reach maturity and cannot be easily replaced. The intensification of development in the District’s urban areas in recent years has resulted in the loss of many fine trees and the provision of adequate space for significant tree planting is often lacking in new developments. To retain and enhance landscape character and quality and secure the environmental benefits that trees provide it is essential that the spatial requirements of trees are adequately provided for in new developments. Existing valuable trees should be retained and protected wherever possible, and adequate new planting of appropriate tree species should be undertaken to provide future trees of stature. Pest and diseases

Trees have been subjected to attack by fungal and bacterial pathogens as well as insects and animals for millions of years. They also have to contend with competition from other plants as well as enduring activities such as highways works and grass cutting. In most cases, trees are able to withstand this pressure, although inevitably some can succumb when they become weak through old age or factors such as drought.

‘Dryads Saddle’ decay fungus


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If a tree becomes structurally weak due to decay, it can sometimes be retained by crown reduction management & monitored thereafter although the viability of such management is dependent upon tree species and the level of public usage around it. If significant pests or diseases are found within trees, these are recorded in the Council’s tree management database and any appropriate measures taken. Climate change brings about challenges from exotic pests from overseas as well as being a potential threat to some trees such as Beech that do not thrive well in prolonged dry conditions. Some trees for example Horse Chestnut are under threat at a national scale due to Bleeding Canker (Pseudomonas syringae pv aesculi) as well as the leaf miner (Cameraria ohridella) and may start to disappear unless large scale treatments become viable. Oak decline and sudden Oak death is also of national concern. This is believed to be caused by the fungus (Phytophthora) and is leading to a number of trees developing bleeding cankers. Our ‘White’ Oaks (Q. robur & Q petraea are however believed to be less susceptible to sudden Oak death although they are affected by Oak decline. Budgets Budget controls following the recent recession will place downward pressure on all council department’s expenditure including that for trees. This may mean priorities have to be set for types of work carried out although planting should be maintained or increased where possible. Savings can be made for example by purchasing smaller stock and maximising the use of mulch to reduce the need for watering. External funding through promotion of the existing tree sponsorship scheme would also help fund new planting.

Legislation Since the original District Tree Strategy in 2004 there have been several changes in legislation that affect the management of trees and species that use them for shelter. These changes affect both council and privately owned trees, and trees that are subject to statutory protection. A brief summary of the most relevant changes are outlined below:

• Tree Preservation Orders (TPO) – in October 2008 the 1App Planning Portal was brought in by the government which introduction a standardised application form for work on protected trees. Further changes to the TPO legislation are currently out to consultation, with the removal of the ‘dying’ exemption one of the likely changes.

• High Hedges – on 1st June 2005 the High Hedges Regulations were introduced

under part 8 of the Anti-Social Behaviour Act. These regulations give council’s the power to act as an adjudicator when a hedge is ‘so much a barrier to light or access as A) is formed wholly or predominantly of a line of evergreens or semi-evergreens and B) rises to a height of more than 2m.’ High Hedges complaints are dealt with by this council’s Environmental Services department.

• The Conservation of Habitats and Species Regulations 2010 – these new regulations consolidate and replace the previous Habitats Regulations 1994, 2007 and 2009. The regulations identify European Protected Species (EPS) and outline


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Policy 7: The Council will aim to maximise the recycling or utilisation of tree related ‘waste’ created by the Council’s own tree management, and to avoid the use of peat and any other products that can cause harm to the environment.

Policy 8: The Council will endeavour to protect trees and their growing environment from threats such as: loss of and damage to verges, the activities of statutory undertakers and others excavating near trees, and damage from the over-use of road de-icing salt.

Policy 9: The Council will ensure that any ancient and veteran trees for which it is responsible, are retained and protected as special historical, wildlife and landscape features.

Policy 10: Trees will be maintained and reinforced by new planting in areas where shade is needed in public areas.

Street Trees

In the last few years, the Council has carried out a comprehensive survey of all highway trees and trees on council land and is now developing a more proactive approach to the management of the tree stock. The Council also now manages all the District’s 11400 street trees under an agency agreement with the County Council. Trees on rural footpaths are maintained by the County Council. In addition, Harpenden Town Council maintain the trees and greens adjoining the A1081 in Harpenden. The roadside environment is a tough place for a tree to survive. There is often intense pressure for space from underground cables and pipes, traffic, buildings, streetlights, road signs, etc. In addition, the limited space is often polluted by car emissions, road salts, oil

Roadside Lime trees


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and other pollutants that challenge the tree’s survival. Furthermore, the trend for car users to park their vehicles on verges continues, causing rutting and soil compaction, both of which will seriously damage tree roots as well as leaving the verge in an unsightly and unsafe condition. There is also an increasing requirement for off-street parking and subsequent construction of new vehicle crossovers. The character of the street tree population varies considerably in different parts of the District, from the older Victorian / Edwardian planting in roads like Salisbury Avenue in Harpenden , through the inter-war developments such as the Cottonmill estate to the newer, suburban areas such as Jersey Farm. Some trees, in particular oak, originate from earlier hedgerow field boundaries, and have been included within the highway verge. Victorian / Edwardian developments tend to contain trees selected from a limited range of forest type species known to be pollution tolerant. Many of these are managed as pollards. Today we have access to a wider range of small or medium, ornamental trees suitable for restricted sites. Many of our most notable tree-lined streets have tree populations that are over-mature for example Bricket Road in St Albans. Such trees are vulnerable to climatic variations (such as drought), disease and damage. An over-mature population of street trees tends to erode gradually over a number of years as individual trees decline and have to be removed. This generally affects the older areas of the District such as St Peters. In these areas new trees should be introduced between the mature trees where space allows to ensure there will be continuous tree cover in future years. The planting of new street trees is also included within the proposals of the St Albans City Vision. The Council acknowledges the massive contribution that large trees make to the character of the environment and will seek to maintain and safeguard this, supported by new planting of similar species unless conditions dictate use of another type. Policies for street trees

Policy 11: The Council will place a priority on the replacement of ageing street tree populations, particularly where these adjoin major traffic routes, planting large growing trees and new trees where appropriate.

Policy 12: The tree species used for new and/or replacement planting in roads shall reflect the type in use locally, maintaining single species avenues and using large growing species where appropriate. Priority will be given to sites where replacement planting is necessary.

Policy 13: The Council will not support the removal of trees for vehicle crossovers unless the tree is of limited life expectancy or is small enough to be relocated elsewhere. All trees removed will be replaced and all costs will be borne by the crossover applicant.

Policy 14: The Council will support measures that discourage verge parking by road vehicles, and damage to verges caused by adjoining building works.


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Policy 15: The Council will give advanced notice to all interested parties of proposed major tree work programmes such as large scale felling, the introduction of pollarding or the heavier forms of crown reduction.

Policy 16: The Council will aim to maintain continuity in the management of the highway trees under successive agency agreements with Hertfordshire County Council.

Woodlands (Including Wooded Commons)

There are a number of ancient or more recent semi-natural woodlands within the St Albans District, some of which stand on common land, managed for public access, recreation and nature conservation. The Council manages twelve woodland areas, and a further two woodlands within Commons, total area 142ha. The Council’s overall management objectives are nature conservation, landscape enhancement and recreation. The majority of the District’s woodland is made up of Oak, Hornbeam, Ash, Birch, Hazel, Field maple, Cherry and Holly. Some have been traditionally managed as coppice with standards to provide wood for the local area. Such management ceased early last century and many woods have since deteriorated directly through a lack of intervention. The future management of woodlands needs to address the continued problems of neglect, which have afflicted many woodlands nationally for at least 75 years. Through “succession” any piece of land if left alone will revert to woodland. This is the best way to create woodland rather than plant but it also means that some woodlands have created themselves in areas where they impact upon other habitats. Trees sometimes need to be removed in these areas to create biodiversity and/or preserve rare habitat.

‘The Wick’ Wood


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The Council’s woodlands represent a substantial natural renewable resource, but further work needs to be done to enable the sustainable utilisation of timber products. To be viable, possible future initiatives such as wood fuel or biomass would be needed although biomass requires an infrastructure organised over a larger area than one district. Policies for woodlands and wooded commons

Policy 17: The Council will ensure its woodlands have up to date management plans in place and encourage the production of plans for woods in the private sector, in particular those which are County Wildlife Sites.

Policy 18: The Council will ensure that its woodlands are managed as a long term sustainable resource for the public, for education and for nature conservation and biodiversity in line with the Local Biodiversity Action Plan (LBAP 2006), and consistent with the guidelines for safeguarding European Protected species as produced by the Forestry Commission

Policy 19: The Council will offset some of its costs incurred through woodland management by the marketing of a proportion of timber and other woodland products, grant aid and/or their contracts requiring such offsets.

Policy 20: The Council will encourage expansion of the urban woodland in appropriate locations ensuring layout and selection of native species of local provenance to reflect the local woodland character. Natural regeneration will be supported on appropriate sites.

Policy 21: The Council will manage woodland to fulfil its obligation as owners to ensure safety of people and property whilst remembering that woodlands are natural places and the level of acceptable risk must reflect this.

Parks, Open Spaces And Railway Trails

Trees are fundamental to the structure of parks and green spaces. The trees in parks and open spaces are not only important to regular visitors; they are very important contributors to the overall environment of the area, and are especially valuable for providing shade and

Clarence Park


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cooling during hot weather. They are a high value environmental resource that requires active management if they are to survive for generations to come. The nature of the tree populations of the district’s different parks and green spaces is as variable as the character of the sites themselves. At one extreme there are the older parks, such as Clarence Park, with a mature to overmature population of trees including a number of rare and interesting specimens. Open spaces with water courses often contain old pollard and coppice Willow and other species which depending on their condition (and a wildlife assessment) require a resumption of such management. At the other are the newer parks, such as Longacre Open Space, with a limited number of trees and range of species. For this reason the management of park trees has to be planned on a site by site basis, seeking a balanced tree population and a character for each. Tree surveys have been completed for Clarence Park, Rothamsted Park and Verulamium Park. Roadside boundary trees in the majority of the district’s parks have been also been surveyed. The total number of trees and groups found so far is 4,700. More trees remain to be surveyed within the open space interiors. The Council’s Culture and Community Development Department are responsible for the management of the Council’s parks and open spaces and has been working to establish management plans for each site in recent years. A Conservation Management Plan for Verulamium Park was completed in 2008 and includes a Tree Management Strategy. The planting of new trees where appropriate in parks and open spaces would help the Council address the challenges of climate change. The railway trails include the Alban Way which runs through St Albans and Colney Heath to Hatfield, the Nicky Line from Hemel Hempstead, through Harpenden and on to Redbourn, and the Upper Lea Valley Walk, from Wheathampstead to Harpenden. Since the closure of the railways in the 1960s the trails have rapidly been colonised by self sown trees. The trails have become increasingly prominent within the surrounding landscape and form important wildlife corridors. However, in some areas the trees are competing for space with nearby residential and commercial premises and cause difficulties for people. Opportunities for increasing the tree population in these areas are therefore limited, due to the linear nature of the sites and adjacent land uses. Some parts of the railway trails are maintained by the Town and Parish Councils.

Policies for parks, open spaces and railway trail trees

Policy 22: The Council will seek to develop long term management plans for trees in parks and open spaces to identify areas of risk, maximise safety and to prevent decline and guide the planting of new trees for the future.


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Closed Churchyard And Cemetery Trees The issues affecting tree management in closed churchyards and cemeteries are similar to open spaces in a number of areas, but differ in that there are gravestones and memorials to consider. Trees make a valuable enhancement to the landscape in these areas and can be important historically, but can cause problems that include the obscuring of grave structures and disruption by tree roots and branches. Cemeteries in particular have to allocate new graves, or add to existing graves, and this can have an impact upon trees already in situ and/or the scope for future tree planting. Policies for closed churchyard and cemetery trees.

Policy 23: The Council will seek to develop long term management plans for trees in closed churchyards and cemeteries to identify areas of risk, to prevent decline and guide the planting of new trees for the future.

Housing Trees

A large proportion of the public housing sector in St Albans was built during the post-war period. Ornamental and fruit trees were planted after individual type houses were built, and larger trees were planted in the communal gardens surrounding flats, in keeping with the scale of the buildings. Some new trees have arrived through tenant’s own plantings and through natural regeneration from seed. Some of the older estates have progressively lost their original trees and these have not been replaced. . Trees in properties that were sold

Hatfield Road Cemetery


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under the ‘right to buy’ scheme are protected by a covenant that requires the owner to obtain Council consent before felling takes place. Many trees within communal gardens and individual type house gardens are reaching maturity, and are in some cases conflicting with nearby buildings. A common problem is the overuse of cypress type hedging in individual type house gardens. These hedges work well if maintained at a typical garden hedge height. However, if the hedge is allowed to grow unhindered, there can be problems with shade that may in turn cause disputes between neighbours. Often the only solution to overgrown cypress hedging is complete removal as they have limited scope for pruning. Housing tenants are currently expected to maintain their own gardens including trees. The council carries out work in communal gardens, but will only consider works in residential gardens on a discretionary basis. The recent survey of trees in communal gardens in which 3,000 trees and groups were found will enable the more proactive management of this section of the Council’s tree stock. The survey data will also help identify sites for new tree planting to ensure a more varied age structure in the tree population of council housing areas and provide the mature trees of the future. Policies for housing trees

Policy 24: Housing trees in residential gardens are to be maintained by tenants as part of their tenancy agreement, except in cases with the Housing Department’s discretion.

Policy 25: Trees in communal gardens will be managed on a more proactive basis to ensure they fulfil health and safety requirements, do not pose a risk to structures and enhance the quality of the environment.

TREES ON PRIVATE LAND

Tree And Hedgerow Protection

As the Local Planning Authority, the Council has a statutory duty to take steps to protect trees that it believes make an important contribution to the amenity of the area.

Tree protected within a construction site


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Under the Town and Country Planning Act 1990 the Council has powers to make and enforce Tree Preservation Orders (TPO) and designate Conservation Areas (CAs) within which all established trees are protected. It is usually only in cases of potential threat that a local authority will protect trees by use of a TPO. Protection is also achieved through advice to the community from the Council's Trees and Woodlands section, although the Council is unable to give detailed advice regarding the safety and management of privately owned trees. Advice is also readily available from many other sources, but can be inaccurate and may have serious consequences for the tree and its owner. Arboriculture is an established technical discipline where qualifications at various levels are available. Any person offering advice should keep themselves up to date, usually through membership of an appropriate professional body such as the Arboricultural Association and/or by subscription to the Tree Advisory Trust's research notes and reading list. The Arboricultural Association produces a list of approved contractors and consultants who have been examined and found to reach recognised standards. The Council also has a list of contractors that can be issued to members of the public for information purposes. If tree surgery work is carried out be people whose technical abilities are poor, this can lead to low standards of work, which are not in the interests of the tree or its owner. Work should always be carried out by a reputable company to recognised standards of work (such as “British Standard 3998, 1989, Recommendations for Tree work"). Statutory Protection Of Trees The current Town and Country Planning Act 1990 makes it a duty of the Local Planning Authority:

(a) “To ensure whenever it is appropriate that, in granting planning permission for any development, adequate provision is made by the imposition of conditions for the preservation or planting of trees”.

(b) “To make such orders (Tree Preservation Orders) under Section 198 as

appear to the authority to be necessary in connection with the grant of such permission, whether for giving effect to such conditions or otherwise”.

The Council is currently developing its Local Development Framework (LDF). The principal element of the LDF will be the Core Strategy, which will set out the District’s overarching planning policies and strategic site specific proposals. More detailed guidance will subsequently be provided in the Development Policies and Site Allocations Development Plan Documents. The Development Policies Development Plan Document will include a revised and improved policy on landscaping and trees, which will replace saved Policy 74 of the St Albans District Local Plan Review 1994. In the meantime, Policy 74 still applies and is summarized below:

a) Significant healthy trees and other landscape features such as hedgerows, ponds and watercourses shall be retained.

b) Planning applications on sites with significant existing landscaping shall be supported by a full tree survey indicating all landscape features, tree species, canopy spreads, trunk diameter and levels at the base of each tree.

c) Trees shall not normally be severely topped or lopped, or endangered by construction work or underground services. In addition, buildings shall not be sited so that sunlight and daylight is reduced to an extent that would lead to a request for tree surgery.


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d) The Council will make Tree Preservation Orders and/or attach appropriate conditions to planning permissions to safeguard existing trees and ensure that new planting is established and protected.

e) Where appropriate, adequate space for planting must be allowed within developments. In particular, screen planting including large trees will normally be required at the edge of settlements.

f) Detailed landscaping schemes will normally be required as part of full planning applications. Amongst other things they must indicate existing trees and shrubs to be retained; trees to be felled; the planting of new trees, shrubs and grass; and screening and paving. Preference should be given to the use of native trees.

g) Wildlife corridors shall be established wherever opportunities occur. The Council will also be guided as appropriate by the Department of the Environment “Good Practice Guide for Tree Preservation Orders 2000” (and as amended). The current government has also announced that it intends to revise and simplify the TPO making process in the near future. St Albans City and District currently has over 660 Tree Preservation Orders and 18 Conservation Areas. Details regarding protected trees can be found in the Council’s information leaflet entitled: ‘Guidance notes for making Tree Preservation Orders and works to protected trees’. This leaflet is available on the Council’s website, and at the Council offices.

Statutory Protection Of Hedgerows Rural hedgerows are an essential feature within our countryside fulfilling many roles such as; wildlife habitat/corridors; landscape/archaeological features; historical boundary markers; stock containment and food source. Many have been progressively lost in recent decades due to changes in agricultural practice. Since 1997, certain hedgerows can be protected through the Hedgerow Regulations 1997 under section 97 of the Environment Act 1995. If a hedge fulfils a number of qualifying criteria under these regulations, the owner or applicant must give notice in writing to the local planning authority before the hedge can be removed. Failure to comply with the regulations can carry a fine imposed by Magistrates’ court of up to £5000. For anyone convicted in a Crown court, the fine is unlimited. The regulations do not apply to hedges that adjoin a garden and so cannot be relied upon to protect hedges which may now form the boundary of new housing developments. The qualifying criteria for hedgerows are complex and consequently are being considered for review by Government. The current criteria relate to the value of features within hedgerows from an archaeological, historical, landscape or wildlife perspective. Details available from www.legislation.gov.uk/uksi/1997/1160/contents/made . Trees on development sites: One of the most common threats against trees (and therefore a common reason for making a TPO) is the proposed development of land upon which trees are growing. Plans are sometimes submitted showing a relationship between trees and buildings which is totally unsuitable and schemes are frequently amended to ensure that significant trees are properly retained in a workable relationship with buildings services and access roads. The council’s current planning policy 74 deals with this area.


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For trees to be retained successfully within a development site, it is vital that prior to plan preparation they are surveyed by an arboriculturist as per guidance in BS 5837 (2005). Prior to commencement on site, trees should have their root system properly protected from direct and indirect damage such as ground compaction. The protected zone should be large enough to ensure that no disturbance occurs within the crown spread of the tree as a minimum, the distances can vary according to local ground conditions, tree species and health. Successful retention also requires sufficient amenity space to be allowed within developments for people, trees & buildings to co-exist and to avoid problems such as excessive shade or seasonal debris affecting gardens. The selection of the correct tree species used for new landscape planting within new developments is important to prevent trees becoming over-dominant in small spaces and requiring too much maintenance. This can be important for the council if it ultimately adopts these areas for maintenance. Guidance for tree protection within development sites can be found within BS 5837 (2005).

Policies for the protection of trees and hedgerows

Policy 26: The Council will: - i) Seek to protect trees of amenity (and environmental) value. ii) Promote good standards of tree care and woodland management. iii.) Promote good practice for the protection of trees in development sites.

Policy 27: The Council will give consent for works to a tree or woodland protected by a Tree Preservation Order provided it is satisfied that: -

i) The long term health and appearance of the tree or woodland will not be

impaired. ii) The works will not unjustifiably inhibit or prevent the full and natural

development of the tree. iii) The work is necessary to its continued retention and consistent with good

arboricultural practice. iv) In the case of a woodland, the proposed work is consistent with the

principles of sound woodland management. v) There are sound arboricultural and/or safety reasons for the work.

Policy 28: The Council will impose planning conditions to protect trees according to BS 5837 (2005) and subsequent revisions where appropriate.

Policy 29: Any unauthorised works to protected trees will be investigated and enforcement action taken where appropriate.

Policy 30: The Council will resist development which it considers makes inadequate provision for the retention of, or compensation for:


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i) Trees and other woody plants. ii) Natural features, particularly wildlife habitats such as woodlands,

hedgerows, ponds or watercourses.

Policy 31: The Council will continue to protect significant trees by the use of Tree Preservation Orders, and will review all such Orders periodically to ensure they contain accurate information.

Policy 32: There will be a presumption against the removal or destruction of any hedgerow that is considered important according to the Regulations. Any unauthorised works to important hedgerows will be investigated and enforcement action taken where appropriate.

Policy 33: The Council will usually expect new development to contribute to the overall tree population either through on-site structural planting through planning conditions or a ‘Section 106 Agreement’ dedicated to the planting of trees by the Council in the locality including the Watling Chase Community Forest. New woodland planting may be required if the Local Delivery Framework proposes urban extensions into the green belt.

Policy 34: The Council will encourage all major tree owning organisations to adopt best practice in the care of their trees, especially where those trees contribute to the character of the District.

ACTION PLAN Provision of resources to meet the targets set within the action plan.

Action No Staffing and budget resources Implementation Target date

All actions

To consider as part of the budget process, the specifics of implementation of the tree strategy in terms of the staffing and financial resources of the Council.

Dependent on resource availability

Ongoing

Actions for the management of all Council trees.

Action No Proposed Actions for the management of all Council trees Implementation Target date

1.01 (Policy 3)

Completion of tree surveys where applicable (mainly parks, open spaces, railway trails and cemeteries). Highway and communal housing tree surveys are mostly complete. Full resurveys of all council trees at a minimum of five yearly intervals, annual rolling programme.

Highways (County) have allocated £4,100 per year which needs increasing to £11,500 p/a based on a tree population of 11400 trees. Existing agency funds can be used to meet shortfall. Housing. Allocation for resurvey funds recommended (estimate cost = £3000 p/a based on population 3000 trees) Culture and Community: Allocation for resurvey funds recommended (estimate cost = £5000 p/a based on existing population 4700 trees which will increase if more areas are surveyed. A further minimum of £2000 p/a

Ongoing Commence 2011 then ongoing Commence 2011 then ongoing


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year recommended for completing parks tree survey.

1.02 (Policies 3, 5 & 15)

Carry out annual drive-by/walkabout inspections on top of responsive inspections generated by received enquiries to support existing inventory of Council trees in areas of high usage by public or trees requiring shorter inspection cycles to ensure they do not represent a Health and Safety hazard, and subsequently carry out work under the following criteria: a) Dead / dying trees shall be removed where they may be a

safety hazard to areas accessed by the public or adjoin property. *

b) Trees shall be made safe or replaced as appropriate if they are a health and safety risk due to:

i. Disease ii. Storm damage iii. Growth defects iv. Loss of root anchorage v. Loss of structural integrity vi. Persistent branch fall. vii. Major deadwood.

c) Trees near to roads will be pruned to maintain statutory clearance over carriageways and pavements, and given adequate clearance to street furniture.

d) Trees that cause slip hazards by persistent heavy fruit fall on the highway, or cause irreparable damage to a highway surface due to root action, will either receive corrective surgery or be replaced as appropriate.

*Dead / dying trees in wooded areas can be a valuable habitat and shall be left standing where conditions allow.

Highways. Ongoing (Trees & Woodlands) Housing. Areas of high public usage to be identified prior to allocation of resources. Culture and Community: Areas --+of high public usage to be identified prior to allocation of resources.

Ongoing Commence May 2011 Commence May 2011


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1.03 (Policies 1 & 2)

Maintain existing tree planting commitments and seek to promote an increase in tree cover in the district through initiatives such as Watling Chase, partnerships with organisations such as CMS, Groundwork Hertfordshire, The Tree Council (Tree Warden Scheme, National Tree Week), planning agreements and supporting private projects such as Heartwood Forest

Highways 150-170 trees planted per year from existing budget (£13140) Housing £2500 allocated p/a Culture and Community: None at present.

Ongoing Ongoing after 2011 To be agreed by CCD


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1.04 (Policy 4)

Continue to develop the Tree Warden Scheme, encouraging and enabling community involvement in tree planting and management.

Utilise sources of grant aid where available Supported by Countryside Management Service and The Tree Council (Trees and Woodlands Section)

Ongoing

1.05 (Policies 2

& 34)

Create a series of information leaflets (or obtain from another source) for private tree owners and other organisations responsible for tree management.

Ongoing (Trees and Woodlands Section)

Ongoing

1.06 (Policy 3)

Refine the Council’s existing term contract specification to provide up to date standards of tree care.


Ongoing

1.07 (Policies 4 &7)

Update Sustainable practices in tree contracts Ensure that maintenance works make best use of resources by efficient work planning and the recycling of by-product material wherever possible by the following means: a) Brushwood will be chipped and spread in the work area

when conditions allow, or taken for use elsewhere. b) Cordwood will be left stacked in the work area when

conditions allow, or taken for use elsewhere. c) Materials removed from works to be utilised for mulch,

biomass or other appropriate form of recycling.


Ongoing


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1.08 (Policy 7)

Encourage the County Council to investigate the creation of timber stations in the County to improve the utilisation of tree by-products for energy production through biomass, composting of tree waste or charcoal burning.

Additional resource (Trees and Woodlands Section / Environmental Services) resource to be considered as part of the budget process

To be agreed by the affected departments

1.09 (Policy 3)

Improve subsidence risk management by the following measures: a) Review existing and past subsidence claims. b) Ensure that trees with a known claim history are managed

proactively. c) Identify other high risk trees according to geographical ‘hot

spots’ species and proximity to buildings. d) Establish set procedures for dealing with subsidence claims

in line with good practice e) Removal of trees that grow from seed or root suckers that is

likely to cause future conflict with nearby structures. f) Use the most appropriate forms of pruning for trees in high

risk areas. This may involve the use of: i. Crown reduction works. ii. Pollarding or repollarding works.

g) Removal of trees is only carried out if no other measure is effective.

Ongoing (All departments)

Ongoing

1.10 (Policy 8)

Encourage District or County wide adoption of the procedures in the National Joint Utility Council Guideline number 10 (N.J.U.G 10) and any subsequent revisions, to maximise the protection of trees during any nearby engineering works.

(All departments and Hertfordshire County Council)

Ongoing

1.11 (Policy 3)

Encourage all agencies with a responsibility for grass cutting or spraying herbicides on Council land to employ practices that avoid damage to trees.

(All departments and Hertfordshire County Council)

Ongoing


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1.12 (Policy 9)

Identify ancient and veteran trees as special features during any survey of Council trees and ensure that they are subsequently retained and protected from any works that threaten their health and/or appearance. Herts Biological Records Centre should be informed of any trees of particular ecological note.

Ongoing (All departments))

Ongoing

Actions for Street Tree Management

Action No Proposed actions for street tree management Implementation Target date

2.01 (Policies 2

& 15)

Inform residents and their Ward Councillors/Parish Council about any work that will have a significant impact upon the trees in their road such as heavy crown reduction work, or the felling and replacement of a large proportion of the trees.


Ongoing

2.04 (Policy 15)

Seek to negotiate renewal of agency agreement with the County to ensure funding is provided to ensure successful ongoing management of highway trees in the district.

Legal / Trees & Woodlands Section and County Council

2010 / 2011

2.05 (Policies 8 &14)

Investigate the means by which verge parking can be discouraged, either through education, and/or enforcement as well as any physical restraints.

Consider implementation via City Vision (All departments)


Actions for the management of woodlands and wooded commons


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Action No Proposed the management of woodlands and wooded

commons

Implementation

Target date

3.01 (Policies 17

&21)

Create management plans to improve the quality of the urban woodland, particularly where management and planting will help to improve their age structure, appearance and value for people and wildlife. Work in partnership with organisations such as CMS and the Herts & Middlesex Wildlife Trust for the creation of new management plans as well as reviewing existing plans. Encourage the involvement of tree wardens and friends groups from the voluntary sector.

Ongoing/Additional resource Cost dependent upon work programme within management plan (Culture and Community / Trees and Woodlands Section)

Ongoing

3.02 (Policies 19 & 33)

Investigate additional sources of funding for managing woodland open to the public e.g. the Forestry Commission or the Heritage Lottery Fund

Ongoing (Culture and Community/ Trees and Woodlands Section)

Ongoing

3.03 (Policies 20 & 33)

Seek alternative sites and funding for the expansion of woodlands, both from organisations such as the Forestry Commission and from planning ‘Section 106’ agreements, in line with Watling Chase Community Forest objectives and forthcoming Green Infrastructure guidelines.

Ongoing/Additional resource via S106 (Culture and Community / Trees and Woodlands Section/ Planning/Legal)


Actions for trees in parks, open spaces and railway trails

Action No Proposed actions for trees in parks, open spaces and

railway trails

Implementation Target date

4.01 (Policy 22)

Integrate tree management in parks, green spaces and railway trails into individual management plans.

Ongoing Cost dependent upon work programme within management plan (Culture and Community)

Ongoing


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Action No Proposed actions for trees in parks, open spaces and

railway trails


4.02 (Policy 22)

Reintroduce coppice and pollarding regimes for waterside willows and other trees with this past management where appropriate.

Existing resource Cost dependent upon the condition & number of these trees found in surveys (Culture & Community / & Trees & Woodlands Section)

To be agreed by CCD

Actions for trees in closed churchyards and cemeteries

Action No Proposed actions for trees in closed churchyards and

cemeteries


5.01 (Policy 23)

Prioritise replacement planting of declining tree populations. Replace trees with a variety of tree species including native types to ensure diversity, sustainability and historic integrity.

(Culture and Community / Trees and Woodlands Section)

To be agreed by CCD

Actions for Housing tree management

Action No Proposed actions for housing tree management Implementation Target date

6.01 (Policies 24 & 25)

Carry out responsive tree inspections and issue works when requested.

Ongoing (Trees and Woodlands Section / Community Services)

Ongoing

Actions for tree and hedgerow protection


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Action No Proposed actions for tree protection Implementation Target date

6.03 (Policy 31)

Where necessary revoke out-of-date Tree Preservation Orders and serve new ones.

Ongoing Due to reduced resources, priority list applies (Trees and Woodlands Section / Legal Services)

Ongoing

6.04 (Policy 26)

Maintain and promote a list of local tree work contractors for distribution to the public.

Ongoing Ongoing

6.05 (Policy 26)

Seek to involve all members of the community through the Tree Warden Scheme in the protection of trees and hedges.


Ongoing

6.06 (Policies 2 & 26)

Prepare guidelines for developers regarding the protection of trees within development sites.

Existing or additional resource (Trees and Woodlands Section) resource to be considered as part of the budget process

Dec 2011

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APPENDICES Appendix 1 Related documents Appendix 2

Glossary of terms

Appendix 3

Trees And Archaeological Sites

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APPENDIX 1

RELATED DOCUMENTS The following documents contain issues that are relevant to trees within the District:

District Council documents: Sustainable Community Strategy for St Albans District 2009 ‘Shaping our District together for 2021 St Albans City Vision 2009 St Albans Rural Vision 2009 District Local Plan 1994 Conservation Management Plan for Verulamium Park Strategy for Archaeology and Historic Environment TAP Trees Against Pollution, a strategy for tree planting and air quality 2004

Hertfordshire County Council: Green Infrastructure in Hertfordshire: A Framework 2009 Habitat Action Plan for Woodlands 2008/9? Hertfordshire Local Biodiversity Action Plan (LBAP) Review 2006 Hertfordshire’s Woodland Strategy Hertfordshire Landscape Character Assessment Woodlands for life

Government documents Department of the Environment The Hedgerow Regulations 1997. A Guide to The Law and Good Practice Department of Environment, Transport and the Regions (2000) Tree Preservation Orders. A Guide to the Law and Good Practice.

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APPENDIX 2

GLOSSARY OF TERMS

Arboriculture The management of woody plants for environmental and social benefits.

Basal Growth Any shoot or growth arising from the base of the tree, its roots or graft union arising from dormant or adventitious buds.

Conservation Area An area of special architectural interest whose character and appearance is desirable to preserve or enhance. Trees within Conservation Areas have similar protection to those with a Tree Preservation Order.

Coppice

The production of shoots from a cut stump (called a stool) that have been cut before.

Coppicing The operation of felling and regenerating shoots from the stool, generating a regular supply of ‘underwood’. Coppicing can usually be repeated many times and is a useful means of regenerating broadleaf species at short intervals, providing significant structural diversity within woodland.

Crown reduction The shortening of branches making up the crown of the tree in order to reduce its size whilst attempting to maintain a natural shape.

GIS Computer based geographical information system.

Green corridor Habitat areas or features providing linkages between important sites or through both urban and rural areas as well as routes along which wildlife can migrate.

Hedgerow

Regulations

Made under section 97 of the Environment Act 1995 to protect important hedgerows in the countryside.

LNR (Local Nature

Reserve)

An area of land designated by a local authority as being of high natural interest in the locality.

High Hedge

Regulations

Regulations for the control of evergreen hedges in or adjoining residential gardens.

Over-mature The age class of a tree in forestry terms. Such trees are usually becoming aged and may have a limited life expectancy, especially if they are a short lived species. Conversely, long living species can be ‘over-mature’ for many years.

Planning Condition A condition attached to an approved planning permission by a Council that describes how a development should be carried out.

Pollard Similar in practice to coppice, cutting off shoots at 3-4 metres above ground back to previously established pollard points.

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Pollarding Is the operation of cutting and regeneration of shoots at 3-4 metres above ground level. Cutting operations usually carried out in rotation of 2-5 years.

S.S.S.I (Site of

Special Scientific

Interest)

An area of land which in the opinion of Natural England is worthy of protection and is of nationally significant interest due to its flora, fauna or geological features.

Supplementary

planning guidance

Guidance considered as a material factor when determining a planning application.

Tree Preservation

Order (TPO)

An Order made under the Town and Country Planning Act 1990 to preserve trees of amenity value.

Tree Warden Scheme A scheme that uses volunteers with some training to gather information and encourage practical projects relating to trees in the community.

Urban forestry The establishment and management of all the trees and woodlands in a town or city.

TAP Trees Against Pollution, A Strategy for Tree Planting and Air Quality 2004 (awaiting completion). A joint initiative between the Council and Groundwork Hertfordshire to plant trees on sites in the County to help offset pollution from its motorway routes.

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APPENDIX 3 TREES AND ARCHAEOLOGICAL SITES Special conditions apply to trees on archaeological sites, especially those protected as scheduled ancient monuments [SAMs] under the Ancient Monuments & Archaeological Areas Act 1979, since tree roots, or the process of planting/replanting, may disturb the archaeological remains.* Where the Council owns the SAM (including the largest in the county, at Verulamium), it has a responsibility to act in the monument’s best interest, with the Council’s District Archaeologist working in conjunction with English Heritage. Elsewhere, the Council may need to offer advice but SAM decisions will be taken between English Heritage and the landowner. The Council or other landowner can undertake tree maintenance work within a SAM without reference to English Heritage, but is likely to need Scheduled Monument Consent for replanting or new planting. The Council-owned sites principally concerned are

• Verulamium Park

• Beech Bottom Dyke

• Sopwell Open Space The Roman defences in the SE corner of Verulamium Park are however covered by a Deed of Guardianship of 1931 under which English Heritage is now responsible for tree maintenance and most other matters. The Council can call on English Heritage to carry out tree works in this area, or carry them out on English Heritage’s behalf, by agreement. Much work on undergrowth and saplings is carried out by local volunteers with English Heritage supervision. [plan of guardianship area and ancient hedgerows in VP] Wooded areas These comprise the defences (Guardianship site) at Verulamium, and Beech Bottom Dyke. Both areas have been woodland since ancient times, and the growth and regrowth of large trees will not cause unacceptable damage to the monuments. Specifically at Verulamium:

• sycamore has become invasive, and unchecked seedlings can easily cause damage to ancient masonry. Young sycamores should therefore be removed wherever they arise.

• trees should not be allowed to grow within x metres of the front face of the Roman Wall, as roots can damage the masonry

• beech is surviving poorly, especially on the banks where water shortage is most marked, and its shallow root system can create large and archaeologically damaging overthrow holes if a tree is uprooted in a gale. For these reasons beech is unlikely to be a replacement species of choice, despite its majestic growth.

• ash and oak appear to thrive

• squirrel damage is a particular concern, leading to the loss of large branches or whole trees

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At Beech Bottom Dyke, surviving archaeological deposits will be sealed beneath the banks at the top of the ditch, or the deep silts at the bottom. Natural regrowth can be allowed Ancient hedgerows in Verulamium Park Verulamium Park was farmland until 1929, and its wooded hedgerows were retained as an attractive feature. They are probably sixteenth-century in origin, and appear in their present position on a map of 1721. Their mature trees are therefore of the second or third generation. They are of particular archaeological significance since they create a pattern of lynchets in the park – field boundaries which captured displaced ploughsoil, especially on downhill slopes, and can act to protect the archaeological deposits beneath them. The best-preserved Roman mosaics at Verulamium have been found associated with these ancient field boundaries. The field boundaries are currently subject to

• loss of mature trees through various causes, but accidental mechanical damage during mowing contributes. There have been major losses in the past decade, threatening the appearance of the Park

• erosion of the lynchet itself, probably the combined effect of mowing and hill wash (the slow movement of soil particles, worm casts, etc , by gravity). This is demonstrated by trees whose roots now protrude 150 mm or so above ground level

• damage by rabbit burrows and fox earths