Object

Representation ID: 44982

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

ENV4 — Provision, retention and
protection of trees, woodlands and
hedgerows
Taylor Wimpey recognises the important contribution that trees make to the character and
quality Of urban environments and mitigating climate change. However, this needs to be
balanced with the need to make efficient use of land as advocated by the Framework (51241.
part 1 Of the policy requires development adjacent to ancient woodland to provide an
appropriate landscaping buffer, with a minimum depth of 15m and a preferred depth of 50m.
However, theræ is no clear justification for the preferred 50m buffer in the BCP and Taylor
Wimpey considers that this preferred depth should be deleted from the policy.
Part 13 of the Policy ENV4 states that new developments should make a minimum contribution
Of 20% canopy cover across the development site and a recommended contribution Of 30%
canopy cover across the development site. We note that this requirement is based upon
recommendations prepared by the Woodland Trust" rather than being informed by Government
policy and guidance so is not based around any national policy requirement. We consider that
this minimum contribution and recommended contribution are completely unrealistic.
It would be necessary to ensure that this level Of planting would not cause unacceptable harm in
terms of shading and the need to distance dwellings accordingly would have a resultant impact
upon the areas within site where homes can be located. As a result, we consider that the policy
requirement would prejudice the ability for developers to make the efficient use Of land as
required by the Framework It also fails to take into account other policy requirements
which need to be considered in the development of sites and have a further impact upon density,
such as the provision Of open space and highways infrastructure. Taylor Wimpey therefore
considers that Part 13 of the policy should be deleted.
part 14 Of the policy states that new houses and Other buildings must be carefully designed and
located to prevent an incompatible degree of shade being cast by both existing and new trees
that might result in future pressure for them to be removed. Taylor Wimpey agrees with this
approach and considers that the requirements Of Part 13 Of the policy are completely at Odds
with this aim as the canopy cover sought would undoubtedly lead to pressure for trees to be
removed in the future.
Part 15 of the policy suggests that the positioning of trees in relation to streets and buildings
should not worsen air quality for people using and living in them by allowing street level
ventilation to occur. It is not clear how this could be accurately assessed or achieved in practice
and we do not consider that part 15 would be effective. On this basis we consider that Part 15
should be deleted.
Part 18 of the policy requires trees proposed for removal during development to be replaced at a
ratio of at least three for one. There is no clear justification in the Policy or explanatory text for
the additional replacement trees. Taylor Wimpey is concerned that this requirement would
place unnecessary burdens upon developers and could limit the development potential Of
residential sites if land is lost to facilitate the additional planting of trees and hedgerows.
As the wording of the policy states "a ratio of at least 3 for one" this indicates that the Council
could seek a higher provision than the three to one ratio. The justification text to the policy
notes that there Will be circumstances where the ratio Of replacement planting Will be greater
Emergency Tree plan for the — The 2020
th n this — especially in cases where significant / mature trees contributing to the vi
ecological amenity of an area and its character are to be removed.
As this will vary on a site by site basis, it is not possible to ascertain the impact the Policy would
have upon the development potential and viability of sites.
The justification text to the policy states that where a development site cannot accommodate
additional planting, replacement trees will be expected to be planted in an appropriate off-site
location. It is that this approach would be practical and whether it would actually be
implementable in practice as there may be no additional land available within the developers
ownership to provide this off-site mitigation.
The financial and practical burdens placed on developers by the requirements of Part 18 could
impact on the development potential of sites and therefore cannot be seen to be positively
prepared. In addition, the impacts of this policy requirement do not appear to have been fully
considered in the BCP Viability Assessment. 'Ille replacement of trees on a ratio of one for one
is therefore considered to be appropriate and the policy should be amended to reflect this.