Comment

Draft Black Country Plan

Representation ID: 44849

Received: 11/10/2021

Respondent: Ruskin Properties

Representation Summary:

but this raises concerns in terms of technical approval and the adoption of highways with most Highway Authorities currently reluctant to adopt trees within highways and for the potential for large, commuted sums to be endured by the developer if they are accepted.
The draft policy states that large canopied species should be used ‘where possible’. It needs to be recognised that these types of species may not always be appropriate to the front of rear of houses with issues arising from long-term protection due to liveability issues.
It is unclear how the request for a minimum of 20% canopy cover across a development site has been factored in overall in terms of the mounting costs of developments, particularly on brownfield sites. Would the 20% canopy tree cover form part of BNG or is this criterion in addition to BNG? It is often the case that tree planting does not significantly contribute towards an increase in BNG. Has the provision of 10% BNG and 20% tree cover been factored into viability and the percentage provision of affordable housing put forward within Policy HOU3? Have these policy requirements been tested on existing schemes to consider impacts on the delivery of development on sites that are often going to be at the margins of viability?