Yes

ID sylw: 105021

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Yes

No

ID sylw: 105306

Derbyniwyd: 28/02/2025

Ymatebydd: Warwickshire Wildlife Trust

No, the plan should set out a tree canopy target, as other Councils have done, to be more ambitious at a wider scale.

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 Whilst it is noted that the draft guidance, that will support the suggested policy (direction), is a work in progress, the draft policy direction seeks to deliver an additional policy layer (or burden)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.

No

ID sylw: 106668

Derbyniwyd: 05/03/2025

Ymatebydd: Warwickshire Property and Development Group

Asiant : Framptons

While we support the general intent of Draft Policy Direction-42, we do not support the Councils intention that developers will be “expected” to increase tree canopy cover on sites that are the subject of a planning application. We consider that this will be unnecessarily burdensome for developers, especially when considered alongside other policy requirements in the emerging SWLP and consequently could impact on viability. Furthermore, this requirement would have negative implications in terms of a developers ability to increase densities on many sites and would not support an effective use of land in meeting the need for homes and other uses.
Instead of an increase in tree canopy cover on sites being “expected” , we feel it would be more appropriate if the SWLP simply stated that this would be “encourage” by the Councils.

No

ID sylw: 106984

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Homes

Asiant : Savills

The policy seeks to protect trees of ‘value’. It is unclear what the LPA consider is a tree of ‘value’. National policy only seeks to protect irreplaceable habitats which include veteran trees and ancient woodland (NPPF paragraph 193). The SWLP should not seek to protect every tree which is not ‘dead’ or ‘dangerous’. The policy should seek for trees to be protected ‘where possible’.
The policy also states that development will be expected to increase tree canopy cover. We object to this requirement. The feasibility of this requirement as well as its impact on the viability and a site’s ability to be delivered efficiently has not been evidenced and justified. Trees with a large canopy cover need to be properly located on development sites away from proposed built development (e.g. to avoid shading / shadowing and root damage to
hard standing). Therefore, the more trees proposed, the greater the likelihood that the developable areas of a development site will be impacted.

Yes

ID sylw: 107183

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

This DPD is welcomed. There is no mention of the role trees play in delivering BNG nor of the importance of retaining them on development sites, where layouts should be designed around the retention of existing mature trees.

Other

ID sylw: 107280

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 42.
The last part of Draft Policy Direction 42 specifies the standards / strategies / guidance that tree planting needs to be in line with. We recommend that, for proposals in the CNL, this list should also include:
• the Board’s Position Statement on ‘Woodland Creation and Tree Planting in the Cotswolds National Landscape - Tree Species and Provenance’;85
• the CNL Landscape Strategy & Guidelines (within which advice is provided on woodland creation and tree planting within each landscape character type).86
We also recommend that Draft Policy Direction 42 should also explicitly refer to the Government’s guidance for making planning decisions in relation to ancient woodland, ancient trees and veteran trees.87 In particular, we recommend that the Draft Policy Direction should explicitly refer to (and advocate) the buffer zone recommendations that are set out in this guidance.

Yes

ID sylw: 107367

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

Trees, hedges and woodland – The National Trust care for vast numbers of trees, hedges, and areas of woodland within South Warwickshire and they hold significant value in respect of visual amenity, landscape character, habitats, and clean air, and are crucial to tacking climate change. We are supportive of the Local Plan’s policy direction to promote the retention of existing trees, woodlands, and hedgerows in the first instance as these take many decades to mature and realise their full benefits. It will also require the enhancement of sites with new tree planting as part of all development proposals. We are supportive that any proposed loss of trees in areas of historic significance (conservation areas, ancient woodlands, traditional orchards) must be based upon arboricultural evidence.

No

ID sylw: 107390

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

No, the plan should set out a tree canopy target, as other Councils have done, to be more ambitious at a wider scale.
The plan isn’t considered ambitious enough in terms of enhancing new areas and pushing for more than just preservation. The Councils also needs to undertake an update of TPO worthy trees in the area. To protect existing environmental assets, which benefit wider health, wellbeing and tourism.

No

ID sylw: 107761

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The policy seeks to protect trees of ‘value’. It is unclear what the LPA consider is a tree of ‘value’. National policy only seeks to protect irreplaceable habitats which include veteran trees and ancient woodland (NPPF paragraph 193). The SWLP should not seek to protect every tree which is not ‘dead’ or ‘dangerous’. The policy should seek for trees to be protected ‘where possible’.
The policy also states that development will be expected to increase tree canopy cover. We object to this requirement. The feasibility of this requirement as well as its impact on the viability and a site’s ability to be delivered efficiently has not been evidenced and justified. Trees with a large canopy cover need to be properly located on development sites away from proposed built development (e.g. to avoid shading / shadowing and root damage to hard standing). Therefore, the more trees proposed, the greater the likelihood that the developable areas of a development site will be impacted.

Other

ID sylw: 107864

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

Other

ID sylw: 107890

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

It is noted that there is a presumption in favour of retaining trees, this is supported.
However, the policy only recognises that the removal of trees meeting specific criteria i.e. TPO’s, trees in conservation areas, will only be allowed where there are sound arboricultural reasons for removal. This is generally supported, however, the policy should also recognise that there may be an instance where a tree needs to be removed to provide a specific requirement of development, for instance, where removal is required to facilitate an access point. The policy should expand the acceptable justification for removal, instead setting out that in instances where it is essential for infrastructure delivery, all other options should be explored before the removal of specific trees is permitted, and its removal weighed in the planning balance.

Other

ID sylw: 107984

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

Other

ID sylw: 108095

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

No

ID sylw: 108238

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

No

ID sylw: 108254

Derbyniwyd: 22/06/2025

Ymatebydd: Sovereign Man Simon of the family Thomas

No, the plan should set out a tree canopy target, as other Councils have done, to be more ambitious at a wider scale.

No

ID sylw: 108478

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

While we support the general intent of Draft Policy Direction 42, we do not support the Councils intention that developers will be “expected” to increase tree canopy cover on sites that are the subject of a planning application. We consider that this will be unnecessarily burdensome for developers, especially when considered alongside other policy requirements in the emerging SWLP and consequently could impact on viability. Furthermore, this requirement would have negative implications in terms of a developers ability to increase densities on many sites and would not support an effective use of land in meeting the need for homes and other uses.
We note that the justification provided in support of the Draft Policy Direction simply refers to the Local Authorities having a statutory duty to consider the protection and planting of trees when granting planning permission for proposed development, as set out section 197 of the Town and Country Planning Act 1990, and paragraphs 136, 187, and 193 of the NPPF. No similar justification is provided for developers being required to increase tree canopy cover on sites.
Consequently, instead of an increase in tree canopy cover on sites being “expected” , we feel it would be more appropriate if the SWLP simply stated that this would be “encouraged” by the Councils.

No

ID sylw: 108598

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.

The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.

Other

ID sylw: 108644

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 42 – Trees, Hedges, and Woodland
10.12.
The policy direction states that there should be a presumption in favour of retaining existing trees and hedgerow on site. In the list of instances in which removal can be acceptable, the removal of low-quality trees and hedgerow which may be constraining development (i.e. those classified as Category C and Category U, which lack value and have a limited life expectancy) should be added, where this loss can be justified and compensatory planting provided. For example, removal may be necessary to create safe and suitable access into a site, or to make an efficient use of land, in line with the NPPF.
10.13.
The Councils are also proposing that development will need to increase tree cover and be supported by a tree canopy assessment. The policy should recognise that there may be sites and types of development for which scope to increase tree cover is very limited, or not feasible at all. As such, whilst a policy encouraging proposals to include new tree planting is supported, this should not be mandatory.