Support

Representation ID: 23429

Received: 15/02/2022

Respondent: L&Q Estates

Agent: Barton Willmore

9.6 L&Q Estates are supportive of Draft Policy ENV4 for the provision, retention and protection of trees, woodlands and hedgerows. Part 3 of Draft Policy ENV4 advises that where removal of trees is unavoidable, replacement trees should be provided to compensate for their loss, on a minimum basis of three for one.

9.7 Part 6 of Draft Policy ENV4 states that all available data on extant tree cover and associated habitat will be considered when making decisions on the proposed loss of trees and woodland to accommodate infrastructure and other development proposals. In areas where evidence demonstrates that current levels of tree cover are low, proposals that incorporate additional tree planting, to increase existing levels of habitat and canopy cover, will be considered positively, as part of the wider contribution to biodiversity net gain. We are supportive of this pragmatic approach to loss of trees in the context of biodiversity net gain. However, it is considered that Part 6 of Draft Policy ENV4 conflicts with the aims of Part 3 within the same policy, which specifically requires replacement tree planting to compensate for any trees removed, as opposed to assessing the wider opportunities for biodiversity net gain. Therefore, further clarification is required in relation to which part of Draft Policy ENV4 would be applicable to strategic allocations, including the Site (Draft Policy WSA4).
9.8 Part 12 of Draft Policy ENV4 requires new tree planting to be included in all new residential developments, as street trees or as part of landscaping schemes. We support this requirement and can confirm that the development of Site would provide significant tree planting.

9.9 Part 13 of Draft Policy ENV4 requires 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. Whilst it is important to ensure that development proposals include new tree planting, this cannot result in schemes becoming unviable. We would therefore recommend that Part 13 of Draft Policy ENV4 is amended to confirm that this contribution can be reduced subject to viability considerations or confirm that the Black Country Authorities would accept tree planting in an appropriate off-site location.

9.10 Part 24 of Draft Policy ENV4 identifies that there will be a presumption against the wholesale removal of hedgerows for development purposes, especially where ecological surveys have identified them to be species-rich and where they exist on previously undeveloped land. Whilst L&Q Estates appreciate the aims of this policy, it should be noted that some developments will require the loss of some hedgerows to gain access. As set out in the Vision Document (Appendix 2), access to the Site will be taken from the A34 Stafford Road. Map 3 of the Birmingham & Black Country Local Sites Assessment Report for the Site identifies that the Site’s western boundary along the A34 comprises hedgerow with trees. Where access to the Site and the associated visibility splays are required, some of this hedgerow will need to be removed. Given the access would not result in the wholesale removal of the hedgerow, it is considered that this would be in accordance with Part 24 of Draft Policy ENV4