Object

Draft Black Country Plan

Representation ID: 21483

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Representation Summary:

Policy ENV4 – Provision, Retention and Protection of Trees, Woodlands and Hedgerows

6.5. The requirement within this emerging policy is that replacement tree planting should be provided on a three for one basis as a minimum. This is not considered to be an appropriate requirement for every site as there may be instances where removal of trees is justified, for example due to the poor condition of particular tree specimen, and where the particular specimens does not justify such a level of replacement planting. The replacement of poor specimen trees on a development site should not be absolutely required at this level, particularly if it would harm the development capacity. In such circumstances funding toward off-site provision should be equally supported.

6.6. The level of detail proposed within Policy ENV4 is also considered to be unnecessary and inappropriate. Whilst it is important to ensure that appropriate provisions are included within the policy, it is considered that there are provisions within the policy that area already covered by best practice guidance and/or other regulations. For example, the detail regarding tree planting on site, and the need to ensure the protection of trees during development. The policy should not reproduce such requirements unless it is considered specifically necessary and justified in accordance with the provisions of the National Planning Policy Framework.