Object

Representation ID: 43878

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

11.10 Policy ENV4 seeks to provide, retain and protect trees, woodlands and hedgerows. Taylor Wimpey supports the principles set out in the policy and to delivering new tree planting in association with development proposals. However, there are certain specific elements of it that raise concern. In particular Criterion 12 states that development proposals should use large canopy species where possible. This is not support as it will often cause conflict with Highway Authorities, where they be located along new streets, particularly where they are likely to be frequented by high sided vehicles. Similarly, the policy refers to making a ‘minimum’ contribution of 20% canopy cover across a development site and a ‘recommended’ contribution of 30% canopy cover across a development site. Such an approach would have a significant impact on the capacity of any new development site. Furthermore, these specific figures are arbitrary and have not been justified. Consideration has not been given to its implications for delivery of housing or employment development. This element of the Policy should be deleted as it is not properly evidenced and it would sterilise large tracts of land which has development potential. It would also be in addition to requirements of other open space typologies- areas for sport and recreate cannot accommodate tree cover as envisaged.
11.11 Criterion 14 refers to new houses and buildings being carefully designed to avoid shade cast by both existing and new trees. As creating shade with trees is one response to climate change and combating the urban heat island effect, the inclusion of this criterion needs further clarification and justification.
11.12 Criterion 18 refers to trees proposed for removal during development being replaced at a ratio of at least 3 trees for 1 removed tree. It goes on to state the size and number of replacement trees would be commensurate with the size, stature, rarity and amenity of the tree to be removed. This approach is unreasonable, not justified by evidence and does not properly consider the practicalities of providing replacement trees particularly when larger specimens can be difficult to establish. This criterion should be deleted.
11.13 Criterion 22 refers to utilisation of planning conditions to require an arboricultural Clerk of Works being required on sites where development will potentially impact on trees. It is unclear how this requirement will be enforced on the ground. Similarly, Criterion 23 states a presumption will be applied to replacement trees being from the UK and Ireland to negate the spread of tree pests and diseases whilst supporting regional nurseries. The evidence base for this requirement is questioned. Similarly, it is difficult to understand how this would be enforced via planning conditions or through a planning permission. It could also mean trees are difficult to resource in the planting season.
11.14 Criterion 24 states there will be a presumption against the wholesale removal of hedgerows for development purposes. Taylor Wimpey supports the principle that established hedgerows should be protected in development proposals. However, particularly when dealing with greenfield sites such as those in the Neighbourhood Growth Areas, it is inevitable that some hedgerows will need to be removed to facilitate other requirements such as access, circulation routes, drainages etc and the policy should be amended to reflect that there are occasions where hedgerows can legitimately be removed to secure other planning objectives. Criterion 27 states new hedgerows would be sought as part of site layouts and landscaping schemes. This policy should be revised to reflect differing circumstances within the Black Country whereby not in every occurrence would it be appropriate to plant a hedge particularly in urban/town centre locations.