BASE HEADER

No

ID sylw: 106440

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

Draft policy direction 42 sets out that the councils will resist the loss of trees of value apart from where the tree is dead, dying or dangerous (i.e. where it is good arboricultural practice to remove). The draft policy direction includes a presumption in favour of retaining and enhancing existing trees, woodland and hedgerow cover on site and sets out that development will be expected to increase tree canopy cover, supported by a tree canopy assessment in line with guidance that is to be developed. Whilst it is noted that the draft guidance, that will support the suggested policy (direction), is a work in progress, the draft policy direction seeks to deliver an additional policy layer (or burden) and duplicates other policy requirements (around BNG in particular) and indeed duplicates arboricultural best-practice in any event. At the very least, flexibility is required for any policy to be effective, recognising that increasing tree canopy cover (for example) will not be necessary or justified in all developments proposals. Additionally, Porterbrook’s response to draft policy 38 (BNG) highlights that the current requirement for a minimum of 10% BNG is already a significant barrier for some development proposals to achieve, and in some cases makes development unfeasible and unviable. With this in mind it would not be justified or effective for the swlp to include a further policy requirement in the form of a tree canopy assessment (for example) where this is already required by policy in any event. In conclusion, the draft policy direction is duplicating requirements that are already included in other national and (draft) local policy, and legislation. As such it is not justified or effective.