Comment

Representation ID: 21270

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows
Point 3 of the Policy states that there is a presumption against the removal of trees unless there are sound arboricultural reasons to support their removal. We assume that ‘arboricultural reasons’ will include tree categorisations (Categories A, B, C and U). The NPPF only places a presumption in favour of protecting Ancient Woodland and Veteran Trees (paragraph 180). We therefore consider that this policy should not seek to protect all trees on a site and lower quality trees (Category C and U) should not be afforded the same weight as a veteran or Category A tree. Additionally, we consider that site constraints / layout should also be noted as potential reason for removal subject to replacement planting.

Point 10 should state where possible in regards to designing a scheme to incorporate existing trees already present on site.

Point 11 states that mature / ancient / veteran trees should be retained on site. In order to comply with national policy, we consider that the policy should state “subject to wholly exceptional reasons and a suitable compensation strategy” (NPPF paragraph 180d).

Point 12 states that new developments should use ‘large canopied species’ and street trees will be pursued. The PPG sets out guidance on what should be considered when assessing tree proposals and “the selection of street trees needs to consider which species will best suit the highway environment in the long term, including associated infrastructure and utilities” (Reference ID: 8-029-20190721). We consider that these considerations are important to the delivery of a site and should be added as a consideration within Policy ENV4. Further confirmation is also sought as to whether the cost of the Highways Authority maintaining tree lined streets has been factored into the viability appraisal as from Savills’ experience elsewhere in the country it could be as much as £30,000 per tree.

Point 13 states that 20-30% tree canopy cover will be sought on site. We object to this requirement for a number of reasons. Firstly, it is unclear how canopy cover will be calculated across the site and how this can be deliverable for residential sites which will include private gardens where there is limited / no control on what is planted or removed unless the site is within a Conservation Area. Additionally, we consider that this requirement, in combination with others proposed in the plan (e.g. 10% net gain, national requirement for tree lined streets and 3 to 1 replacement tree planting) will have serious implications on the net developable area of the site and as the BCA cannot currently meet its housing needs, this may result in an even greater shortfall and additional sites will be required to meet this shortfall.

Point 18 states that a ratio of at least 3 to 1 for tree planting will be sought. It is unclear how this requirement will work with Point 13 which seeks to require large canopy trees which you would expect would limit the number of trees that could be delivered across a site. We consider that trees which have been assessed as low quality (Category C and U) should not be afforded the same weight as higher quality trees and similarly, should not be required to be mitigated by a ratio of 3 to 1. Additionally, this is a significant replanting figure and we consider it will have implications of the net developable area of a site which in turn could impact on the potential yield of strategic allocations.