Comment

Draft Black Country Plan

Representation ID: 21350

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Representation Summary:

POLICY ENV4 – PROVISION, RETENTION AND PROTECTION OF TREES, WOODLANDS AND HEDGEROWS
Whilst the intention of Policy ENV4 to provide, retain and protect trees, woodlands and hedgerows is recognised, it is noted that the policy is particularly lengthy. It would instead be more suitable for this guidance to be included in a Design Supplementary Planning Document (SPD) or an appendix to the plan. Indeed, that would align with the Government’s PPG on plan-making that specifies that SPDs “should build upon and provide more detailed advice or guidance on policies in an adopted local plan.”

Notwithstanding that, it is suggested that more flexibility be built into the policy. In particular, whilst the overarching aim to retain existing vegetation is recognised, in some cases small-scale removal of trees and hedgerows subject to arboricultural considerations is necessary – for example to facilitate access on greenfield sites. As such, it is suggested that the policy should be amended to require that trees and hedgerows are retained “wherever possible”, which would be a more sensible approach to protecting existing vegetation whilst not restricting development.