Comment

Representation ID: 1327

Received: 28/11/2024

Respondent: Home Builders Federation

Policy DLP34: Provision, Retention, and Protection of Hedgerows is considered unsound by the Home Builders Federation (HBF) due to a lack of justification, effectiveness, and alignment with national policy.

Redundancy of Criteria: HBF questions the need for criteria one in the policy, as it appears to repeat existing national legislation and protection for hedgerows. This redundancy makes the policy less necessary at the local level.

Interaction with Other Policies: HBF expresses concerns about how this policy interacts with other policies, particularly Biodiversity Net Gain (BNG) and nature conservation. For example, if hedgerow removal is needed to access a site, it may conflict with BNG policies that require a 10% net gain from the pre-development baseline. Any loss of hedgerows would need to be compensated under BNG, and HBF suggests this relationship needs clearer clarification.

Need for Flexibility: HBF advocates for more flexibility in the policy. They argue that certain situations, such as site access, may require hedgerow removal, and this should be accounted for in a way that doesn’t undermine the broader environmental objectives.

Interrelationship Between Policies: HBF calls for the interrelationships between various environmental policies (BNG, nature conservation, and hedgerow protection) to be fully considered and explained. The current wording of the plan is unclear, which could lead to confusion for developers and make it harder to deliver projects effectively.

In summary, HBF believes the policy is unclear and ineffective in its current form and recommends greater clarity on how it interacts with other environmental policies to ensure it doesn't hinder development.

Comment

Representation ID: 1369

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP34 is followed by a passage in italics, as to future policy. Future policy is inevitably unknown, but planning applications are dealt with according to policy at their date of submission, but we see no reason why applicants cannot be required (as policy) to comply with the latest position, whatever it may then happen to be.
Instead add to policy:
6. Applicants will be expected to comply with any new enhanced guidance and scientific evidence on hedgerows that become available during the lifetime of this plan.

Comment

Representation ID: 1483

Received: 29/11/2024

Respondent: Canal and River Trust

Stress the need for policies to protect trees, woodlands, and hedgerows, specifically asking for cross-referencing to Canal Policy DLP36 to ensure proper policy application for canals.

Comment

Representation ID: 1552

Received: 29/11/2024

Respondent: Historic England

The policy could also refer to the retention of hedgerows on historic landscape considerations and where the hedgerow makes a contribution to the significance of heritage assets and the wider historic landscape they are experienced within.