Full text of a letter from Cllr Caro Wild, Cabinet Member for Strategic Planning and Transport to Cardiff Civic Society received on 20 February 2020 in response to a letter and a meeting earlier that month
Dear Cardiff Civic Society,
Many thanks for meeting recently to discuss your concerns about the council’s planning department’s approach to trees. I found it really useful, and I know officers have found input from yourselves and other likeminded partners over the years really helpful.
Whilst I share your concerns about any removal of trees, and having spent a great deal of time looking into the issue, I am satisfied that the Council’s policies, approach and actions with regards Green Infrastructure and trees are robust and respond positively to the current national policy context. But we have announced that we will be undertaking a full review of our LDP, which will give us the timely opportunity to look at new policy.
This council and its planning department are extremely passionate about trees and the natural environment, and many of our officers have chosen their profession because of their concern for the environment. But this passion and desire to preserve and enhance does have to work within a strict planning process, overseen by national government. The council has to follow approved national policies and our own Local Development Plan, if we don’t we risk losing any appeal that could be made to the planning inspectorate.
To protect trees we have developed a number of documents to help developers understand our aims and ambitions for the city. These Supplementary Planning Guidance documents (SPGs) and Technical Guidance Notes (TGNs) are clear expressions of what we expect as a council. They enable us to set the standards we expect developers to aspire to and we also use them in negotiations with developers. Developers are expected to use this guidance in drawing up plans before any decisions are made. If they don’t they have less chance of approval.
I am impressed at the scope and detail of the coverage of the Green Infrastructure SPG and the supporting Technical Guidance Notes (TGNs) listed below:
- Ecology and Biodiversity TGN;
- Protection of Public Open Space TGN;
- Public Rights of Way and Development TGN;
- River Corridors TGN;
- Soils and Development TGN; and
- Trees and Development TGN
Collectively, these documents amount to over 450 pages and provide a particularly comprehensive approach in adding detail to policy within the LDP. I therefore remain satisfied that the existing Green Infrastructure SPG including the 6 supporting Technical Guidance Notes (TGN’s) remains fit for purpose and is an exemplar policy approach to promoting green infrastructure, biodiversity and the resilience of ecosystems.
More specifically, the Trees and Development TGN directly addresses the potential implications of climate change. The central message it promotes is the preservation and enhancement of a sustainable urban forest and it explains how development can best contribute to this. A whole section is dedicated to trees and wildlife and identifies the particular attributes of different trees in terms of benefitting wildlife and being well adapted to the predicted impacts of climate change. The Trees TGN must be read in conjunction with the Soils TGN since the two are intimately linked. Without functional soil trees cannot grow, and without trees or other vegetation cover, soil functionality will suffer. Healthy, functional soil is critical to mitigating the predicted impacts of climate change, including supporting the growth of large, long-lived trees. The Soils and Trees TGNs were praised and welcomed by a wide range of interested parties on their release, including members of the public and professionals involved in arboriculture, landscaping and soil. The Soils TGN is unique within the UK and a recent meeting of the ‘Sustainable Soils Alliance’ suggested it is adapted to a generic template to serve as best practice planning guidance for the protection of urban soils.
Any potential loss to trees or habitats will always be very carefully assessed. Officers will take account of quality, condition, age and contribution of features along with the potential benefits of proposed enhancements, mitigation or replacement planting. Decisions are always based on the best possible information in this regard with the categorisation of trees according to their condition helping this assessment. I would stress that the Decision Reports justify the conclusions reached and would explain the rationale for any changes to existing tree coverage as part of proposals.
The Council has also been at the forefront of promoting the masterplanning approach to deliver high quality major developments and creating places where people want to live. For example, the Plasdwr development is being delivered in accordance with a robust framework set out in the Local Development Plan (LDP), and consequent planning consents and Section 106 Agreements. Examples of the benefits of its Green Infrastructure-led approach include:
- Retained woodlands and habitats linked through a series of ecological corridors which also provide safe sustainable access routes to local facilities;
- Provision of ‘ecotones’ to existing woodlands to give breathing space to new development and the creation of a new habitat;
- Provision of sustainable drainage features as integral features of open spaces alongside key roads and cycle routes; and
- Providing new habitats and features to support existing species such as woodland bird assemblage, barn owls, breeding bird assemblage, bat assemblage, great crested newts and reptiles.
I am fully aware of the obligations of public bodies in delivering our Duties Under Section 6 of the Environment (Wales) Act. Working with colleagues across all disciplines, I presented the Cardiff Biodiversity and Resilience of Ecosystems Duty Forward Plan to my Cabinet Colleagues in September of last year. Included within the Forward Plan is an Action Plan which defines the actions we as an Authority, along with partner organisations, are taking in meeting our duties. This is an ongoing process and I am pleased that the Council is fully committed to continue this work over the years ahead.
In terms of keeping our policy framework up-to-date, the Council has commenced work on the full review of our current LDP. This will provide the timely opportunity to consider our future Planning Policy framework for all topics including Green Infrastructure and trees. In this respect, please be aware that Welsh Government guidance states that new policy cannot be set through Supplementary Planning Guidance (SPG), but is set through the Replacement LDP process – as an SPG only provides more detail on how policies are to be implemented as opposed to adding additional policy requirements. In this respect, it is not considered appropriate timing to review current SPGs. Once new policies have been established through a Replacement LDP process, new SPG can be prepared to work up the detail of the new policy framework. This will happen as quickly as possible, within the prescribed statutory timescales.
In the meantime I have asked the Head of Planning to provide me with regular briefings on any potential developments that may significantly impact on trees, so I can be assured all relevant guidance and policies are fully addressed throughout the process.
I would add that I have the upmost respect for the work of passionate and professional officers across different service areas in the Council. This hard work and dedication is not always recognised or understood.
Y Cynghorydd/Councillor Caro Wild
Aelod Cabinet dros Gynllunio Strategol a Thrafnidiaeth
Cabinet Member for Strategic Planning & Transport