Object

Representation ID: 21208

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows

Whilst our Client recognises and supports the BCA’s aspirations to increase tree canopy cover across the Black Country, it expresses reservations around the obligations of Policy ENV4 in this regard, specifically parts 2 and 13 of this policy which require:
• a buffer around individual veteran or ancient trees likely to be impacted by development of a minimum of 15 times the diameter of the tree, approximately 5m from the edge of the tree’s canopy if that area is larger than 15 times its diameter; and
• new developments to make a minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site.

We understand that these requirements stem from recommendations contained within the Emergency Tree Plan for the UK (2020), prepared by The Woodland Trust. We would note that, whilst useful, this piece of guidance is not statutory in nature, nor has it been produced for or by the Government. In such instances, it would be unrealistic to expect developments to adhere to such guidance. Moreover, by necessitating a ‘one size fits all approach’ for the contribution developments make to canopy cover, this part of the policy fails to take into account on-site conditions which could mean this cannot be achieved. Such conditions should not jeopardise future development across the Black Country, particularly in the context of such an acute need for housing and employment land. We therefore recommend that the policy wording be revised so that canopy cover is determined on a site-by-site basis.