We generally support the policy to improve tree canopy cover and the tree population. This notwithstanding, the proposed policy direction does not allow for site specific allocations or constraints, where a balanced planning judgement should be advocated. Moreover, the policy direction requires in the first and second bullets, the preservation, protection of both the tree population and tree canopy cover on sites, whilst the third bullet point seeks the protection of existing trees of value. In order to provide clarity, the policy direction should make it explicit that trees of value should be protected as opposed to the blanket protection of all tree cover on sites. This comment is made in the interests of securing sustainable development and making the most efficient use of sites, especially those that are previously developed, in sustainable locations. This in turn, will assist in reducing the amount of greenfield land released for housing and other uses.

Furthermore, the policy direction does not make allowance of the ‘planning balance’, and the policy directions and guidance provided elsewhere within the emerging Local Plan and Supplementary Planning Guidance, for example making the most efficient use of land and providing development that maintains and enhances its surrounding character, including the street frontage design, highway network improvements.

Moreover, the policy direction is considered (site specific circumstances) to conflict with the policy direction requirements of Policy GP/QD, especially where sites are bordered by trees (value dependent)where for example, “buildings are required to be orientated to provide natural surveillance and maximise opportunities to create active ground floor uses”.

In this respect, it is considered that text as contained within the opening paragraph of Policy 71 of the adopted Local Plan should be carried across to the emerging policy.