Object

Representation ID: 44764

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

The benefits of tree planting and their role in the Government’s target to reach net zero by 2050 has been widely publicized. It is commendable that the Council is looking to engage proactively with this matter in the Local Plan.

We note that there is a requirement for all sites to provide a minimum tree canopy cover of 20% of the site area and a recommended level of canopy cover of 30%. It is also noted that the tree planting requirements are expected to be met within the development site and there appears to be no opportunity to provide tree planting off site.
The aim of the replacement tree planting standards would appear to be a long term increase in tree cover rather than like-for-like replacement which will be an impediment to building at higher densities, particularly on previously developed sites in urban areas. This appears to run contrary to Policy HOU2 which encourages the efficient use of land in sustainable, urban environments. While we appreciate there are benefits to providing trees in urban areas, building at higher densities in these locations greatly reduces greenfield land-take and is a highly sustainable outcome accordingly. A reduced tree standard for sites in urban areas would be more appropriate.
Given the significant requirement for tree planting we are surprised that there was no allowance made for tree planting within the Local Plan Viability Assessment. We would respectfully remind the Council that the PPG states that “The role for viability assessment is primarily at the plan make stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic and that the total cumulative cost of all relevant policies will not undermine deliverability of the Plan.” Para 002 Ref ID: 10-002-20190509
Recommendation:
3) Reduce the requirement for additional tree planting in urban areas
4) To include an allowance for tree planting, green walls/roofs in the Local Plan Viability Assessment.