Comment

Representation ID: 46191

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Policy ENV4 includes a blanket statement that ‘Development should be designed around the need to incorporate trees already present on site, using sensitive and well-designed site layouts to maximise their retention’.

There should be acknowledgement that there will not be the justification for the retention of some trees, particularly in the context of poor specimens and wider development benefit. The policy text should be consistent with the Framework, which says planning policies should ensure ‘…that existing trees are retained wherever possible’ (paragraph 131).

The policy also sets out at ENV4 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’. It is noted that this is based upon the Emergency Tree Plan for the UK – The Woodland Trust 2020 but there is no basis in the Framework or Planning Practice Guidance for the introduction of blanket thresholds for canopy cover. The same observation is made in respect of ENV4 (18) and its requirement that ‘Trees proposed for removal during development should be replaced at a ratio of at least three for one’. The requirement for replacement trees and the number to be provided should be the subject of site-by-site assessments, alongside a measured consideration of biodiversity net gain.