Comment

Representation ID: 21684

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

1
Comment: WTBBC support that development adjacent to ancient woodland will be required to provide an appropriate landscaping buffer, but request that a larger minimum depth of 25m be required, and that the policy state that only in exceptional circumstances would a buffer of less than 50m be permitted. Furthermore, it should be added that developments adjacent to ancient woodland will be required to be orientated so as to face these in order to reduce negative impacts associated with proximity to residential developments such as the introduction of non-native plant species.
4
Comment: WTBBC request that the evidence used to calculate the target increase in canopy cover to at least 18% over the plan period is published in the BCP.


8
Comment: WTBBC request the wording of this point is changed to reflect and reinforce the importance of following the evidence provided by the Draft Local Nature Recovery Strategy, recognising that tree planting is often not the most ecologically appropriate action. Furthermore, it should be stated that ecosystem services evidence should be produced and followed in order to maximise the benefits of tree planting for biodiversity and climate change mitigation by ensuring this is undertaken in the most appropriate locations.
12
Comment: WTBBC support the recognition of the value of large canopied street trees and that the planting of these should be included in all new residential developments and other significant proposals. This should go further, however, and encourage the planting of new street trees in existing residential and employment areas to maximise the wide range of health, biodiversity and climate change mitigation and adaptation benefits. The opportunity to fund the retro-fitting of street trees through Biodiversity Net Gain contributions should be explored, especially as this is expected to provide resources to manage these for a period of 30 years.
13
Comment: Whilst supporting the minimum contribution of 20% canopy cover across the development site and a recommended contribution of 30% canopy cover across the development site in new developments, this should be caveated to state that this will not be required if this would lead to damage or loss of existing habitats of value that may otherwise be retained.
16
Comment: WTBBC support that replacement trees of a suitable species must be provided on site where planning permission has been granted that involves the removal of these, and that where sufficient and suitable onsite replacements cannot be provided, off-site planting or woodland enhancement must be provided in the near vicinity of the removed tree(s). Off-site street trees of large-canopied species should be added to the options for delivering this compensation.
25
Comment: WTBBC request that it is added to this point that replacement hedgerows should be of a suitable diverse mix of locally sourced native species, and that a resourced maintenance and management programme will be required that will include the replacement of plants that fail within a specified period by plants of a suitable size, species and quality.

26
Comment: Whilst supporting that the protection of hedgerows before and during development must be undertaken, WTBBC request that the policy states a minimum landscape buffer of 25m will be required, and that only in exceptional circumstances would a buffer of less than 50m be permitted.
27
Comment: Whilst supporting the creation of new hedgerows as part of site layouts and landscaping schemes, WTBBC request that it be added that these should be of a suitable diverse mix of locally sourced native species, and that a resourced maintenance and management programme will be required that will include the replacement of plants that fail within a specified period by plants of a suitable size, species and quality.