Upload
others
View
1
Download
0
Embed Size (px)
Citation preview
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 1 of 22
Appeals by Keele Seddon Ltd against refusal of a planning application to
Newcastle under Lyme Borough Council for demolition of existing buildings
and development of 92 dwellings at the Hawthorns, Keele, Newcastle under
Lyme.
Arboricultural Evidence – Keele Parish Council
Proof of Evidence
David Bailey David Bailey BSc(hons), M.Arbor.A, cert. Arb(RFS) Appeal references: APP/P3420/A/14/2219380
APP/P3420/E/14/2219712
Original references: 13/00424/FUL
13/00425/CON
AArrbboorriiccuullttuurraall RReeppoorrtt
50 Chestnut Road, Loggerheads, Market Drayton, Shropshire TF9 4BL Tel: 01630 673216 Mob: 07813 808174 Web: www.oldoaktreecare.co.uk
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 2 of 22
Contents
1.0 Qualifications and experience
2.0 Instructions
3.0 Extent of survey
4.0 Original proposal
5.0 The site
6.0 My findings – issues of amenity
7.0 My findings – regard given to trees designated for retention
8.0 My findings – professional approach to the development
9.0 Conclusions
1.0 Qualifications and Experience
1.1 My name is David Bailey. I am the owner of Old Oak Tree Care, an
Arboricultural Consultancy based on the Staffordshire/Shropshire border. I
have run my business as a contractor since 2004 and progressed to work
as a consultant since 2008. In 2014 I ceased contracting work to
concentrate full time on consultancy work.
1.2 I attained an honours degree in arboriculture at Myerscough College,
Lancashire at an upper second level in 2011 after completing a foundation
degree in arboriculture at merit level from Myerscough College, in 2008. I
attained a certificate of arboriculture from the Royal Forestry Society in
2006.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 3 of 22
1.3 I am a professional member of the Arboricultural Association and hold
professional indemnity insurance to £1 million.
1.4 Old Oak Tree Care is an approved contractor to Shropshire Council and
carries out work for non-government agencies, county councils, town
councils, The Forestry Commission and private individuals.
1.5 In my work as a consultant, I have carried out numerous surveys of trees in
relation to construction, large scale health and safety tree surveys, private
consultancy work and LPA appeals.
I confirm that insofar as the facts stated in my report are within my own knowledge I have made
clear which they are and I believe them to be true, and that the opinions I have expressed
represent my true and complete professional opinion.
2.0 Instructions
2.1 I am instructed by Keele Parish Council to provide independent and
objective opinion in the field of arboriculture concerning the appeal by Keele
Seddon Ltd against an application made to Newcastle-under-Lyme Borough
Council to remove buildings, trees and structures from the current site at
the Hawthorns, Keele and replace it with a housing estate.
2.2 I am instructed to consider the visual impact of the development on the tree
population if the appeal were to be successful.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 4 of 22
2.3 I am instructed to investigate whether trees that are to be retained can be
given the required space, both above and below ground, should the
development take place. This should be in accordance with the relevant
standard, BS5837:2012 Trees in Relation to design, demolition and
construction: Recommendations.
2.4 I am to give my professional opinion on the application and appeal where
trees are concerned.
3.0 Extent of Survey
3.1 This report comes with two appendices, DB/2 is a summary of the evidence
contained here within and DB/3 contains photographs and maps to support
my evidence.
3.2 The survey covers only arboricultural matters in relation to this planning
application and appeal.
3.3 There are two separate planning applications involved in this appeal.
13/00425/CON deals with ‘Demolition of existing student accommodation
blocks and management centre’. 13/00424/FUL deals with ‘Proposed
student accommodation and proposed development of 92 dwellings with
school drop off point, shop and area of greenspace’. As the two applications
are linked (paragraph 1.1 of the Planning Statement of 13/00425/CON), I
will be referring to them from now on collectively as either ‘the application’
or ‘the appeal’.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 5 of 22
3.4 This document deals only with matters arising at the Hawthorns site within
this development. The Barnes site, where student accommodation is
proposed is not in the scope of this report.
3.5 Photographs were taken with a digital compact camera. No manipulation of
images was carried out apart from altering brightness, contrast and
sharpness. Two panoramic views were created using Arcsoft 5 Panorama
maker. Some images were marked to show trees to be removed. These
trees are marked with a red X. Some red lines are drawn where houses are
proposed.
3.6 This investigation took place in the summer months when trees were in leaf.
The site was visited on three different occasions between 11th July and 18th
July 2014. Different views of the site will become available when trees lose
leaves in the winter. A different evaluation of amenity might be made during
winter also.
3.7 Documents I have seen:
i) I have made use of documents for both the appeal and the original
application from Newcastle-Under-Lyme Borough Council’s Planning
Web site
ii) Keele University’s planting map for newly built accommodation dated
12/1/1965
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 6 of 22
iii) Web pages from Keele University in ref to history of Keele Estate
http://www.keele.ac.uk/alumni/keelesheritage/briefhistory/
iv) Tree Report Ref: DFMG/3546/TreeSurveyReport Rev A
v) Tree Survey and Root Protection Area Drawing. Number 3546.01 rev
B
vi) Tree Protection Plan. Number 3546.16 Rev A
vii) Arboricultural Impact Assessment and Method Statement – Trevor
Bridge Associates (tba) Aug 2013
viii) Landscape Visual Impact Assessment Keele University – Barnes
Hall
ix) Letter of 25th September 2013 from Landscape Development Section
in reply to my letter of 18th September.
x) Letter from tba of 6th November re Tree Issues, The Hawthorns
xi) Letter, dated 7th December 2010 from Landscape Development
Section in reference to planning application 10/00531/FUL.
3.8 Item I have not seen:
i) Landscape Structure Plan 3546.09 Revision B. I have been unable
to download a working copy of this document from the council’s
portal.
3.9 I have not taken instructions which are at odds with ethical practice.
3.10 I rely upon the tree protection plan (TPP) within the original planning
application (supplied by Landscape consultants, Trevor Bridge Associates
(tba) and numbered 3546.16 Rev A). I presume this to be correct in the
plotting of tree positions, crown diameter and root protection areas (RPAs).
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 7 of 22
3.11 I rely also upon the tree report as supplied by tba and dated March 2013. I
presume this to be accurate and find on selected trees that the data is
correct. I am also in broad agreement with the quality categories given to
the trees.
4.0 The Original Proposal
4.1 The original planning proposal at the Hawthorns was to demolish the
current student accommodation, built between the 1960s and 1980’s, and
replace it with 92 residential houses, a school drop off point, shop and
linked areas of green space. The Application was made to Newcastle-
under-Lyme Borough Council.
4.2 Using the Tree Protection Plan (TPP) 3546.16 Rev A supplied by tba in the
original application, I counted 166 trees proposed for removal. The total
number of trees on site that appear on the TPP is 306.
4.3 In a letter dated 6th November 2013 from tba to the LPA, it is stated that ‘in
the order of 151 trees across the site would be lost’. The documents to
support this were given as the Arboricultural Impact Assessment (AIA) and
a drawing produced by Pozzoni Architects ref. P3521-104 Rev A.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 8 of 22
4.4 Paragraph 4 of this letter gives special working methodologies required. 4.1
states a number of trees will require the implementation of a cellular
confinement system to allow root protection areas (RPA) to be built upon
without damaging the soil below. Guidance for this is given in Appendix C of
the AIA.
4.5 4.2 of the AIA states a number of trees will require excavations to take
place in RPAs. It is proposed to use an Air Spade to identify roots down to
one metres depth along the required line of construction. Roots less than
25mm in diameter are to be pruned off and roots over this are to be
redirected back away from the construction area if practical to do so.
4.6 The paragraph below 4.2 of the AIA, indicates a similar need to excavate
using an Air Spade as road access is needed in this area and cellular
confinement systems are unusable. It refers back to Paragraph 4.2 to deal
with roots that are encountered.
4.7 A Landscape Visual Impact Assessment has been prepared for the Barnes
Hall site at the university but a similar assessment cannot be found within
the council’s documents relating to the Hawthorns site in this application.
5.0 The Site
5.1 I visited the site on three occasions from 11th July to 18th July 2014 to take
measurements, photographs and assess trees.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 9 of 22
5.2 The Hawthorns site at Keele is currently made up of buildings belonging to
the old Keele estate and newer functional buildings associated with the
university. It is primarily made up of student accommodation blocks built in
the 1960s.
5.3 The Hawthorns site is situated centrally within Keele village and contains
the only shop in the village.
5.4 The trees at the Hawthorns site are generally mature. It appears the site
was part of the wider Keele Hall estate. The size and species of a number
of trees on site would indicate these trees were planted in the late Victorian
era. This would coincide with a time of landscaping and development as
suggested by the university’s web pages on the history of the estate.
5.5 The majority of trees on the site appear to be of an age and species type
that would coincide with the development of the site into student
accommodation during the 1960s.
5.6 From looking at a selection of the trees on site, the trees appear to be of
generally good form, are well managed and will be able to add to the local
amenity for a significant amount of time in the future.
5.7 The trees bring maturity to the Hawthorns site, adding a high amount of
amenity to it.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 10 of 22
6.0 My findings – Issues of amenity
6.1 The site is densely populated with trees, making any development within it
difficult. As trees are a material consideration within the planning process,
the developer has undertaken a tree survey to support the planning
application.
6.2 The original planning documents, as stated in my own paragraph of 5.3, do
not state the number of trees to be lost as being 151. The table within the
Arboricultural Impact Assessment (AIA) does not give the number of trees
in the groups and the architect’s plan pictorially shows trees to be lost or
retained without numbers.
6.3 I have counted 166 trees to be lost out of a total of 306 trees and tba have
stated ‘in the order of 151’ to be lost and have not stated a total number of
trees. To prevent unnecessary argument, I will use the figures of 306 trees
in total counted and 151 trees to be lost. This gives a figure that suggests
approximately half of the trees are to be removed.
6.4 The removal of half of the trees on any site is liable to cause considerable
change to the appearance of it. This is especially so when trees are mature
and large groups of trees are taken.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 11 of 22
6.5 The Barnes site has had a professional Landscape Visual Impact
Assessment completed. The planning application does not include one for
the Hawthorns site.
6.6 I photographed the site from a number of exterior and interior angles. The
positions and photographs are shown from figures 1 to 8. I have indicated
the position where all photographs were taken on a plan of the site in Map
E.
6.7 Some areas, particularly along the immediate boundaries of the western
and eastern sides of the site, are not subject to much tree felling in the plan.
However, within the site and along the northern boundary, tree loss is
heavy and will result in lost amenity.
6.8 Distant exterior views of the site are mainly to be found from the A525. If
travelling in a westerly direction towards Madeley the site is softened by
trees along the eastern border. These trees are, in the whole, destined to
remain in the original planning application. Travelling easterly on the A525,
there are some views of the site particularly around the junction with the
B5044. Figure 1 shows the view from this location. The loss of trees here
would be considered a moderate loss to amenity.
6.9 The site is not visible from Station Road when coming into the village until
relatively far into the built up area.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 12 of 22
6.10 Figure 2 shows the view from the top of Quarry Bank Road. While most of
the trees on the periphery will be retained, the younger trees in the middle
will be lost. This would amount to a small loss of amenity.
6.11 From outside the school, the loss of all of the cherry trees in G20, G22, G23
and G24 will have a substantial loss to the amenity of the area. These trees
soften the view into the Hawthorns site from this well used area. Figures 3
and 4 show this.
6.12 The largest shock to the amenity of the site when viewed from the exterior
of the site is to be found from the main entrance to the site off Station Road.
Figures 5, 6, and 7 show the view from here. From this entrance the loss of
much of G10, all of G29, 6674, 6686, G28, 6668, 6639a, 6657, 6658, G33,
G30, G31 and 6653 will be visible. I would consider this to be an extreme
loss of tree amenity.
6.13 The northern boundary is clearly in view for users of the footpath that cross
from Station Road to the A525. Figure 8 shows the panoramic picture of
this. A considerable number of trees are to be lost here. This will cause a
moderate loss to amenity.
6.14 Within the site a number of trees would be retained whilst some areas will
experience more tree loss. Taken as total amount, I would consider the tree
loss within the site to amount to a significant loss of amenity to the site.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 13 of 22
7.0 My findings – Regard given to trees designated for retention
7.1 Of the 155 trees that are to be retained on site, 18 of the trees will have a
cellular confinement system placed upon their root protection area (RPA)
and 5 trees are designated as having their RPA’s dug into.
7.2 A root protection area (RPA) is an area around a tree that contains the
minimum amount of roots and rooting medium to maintain the viability of the
tree. This area is prioritised for the tree. The size, shape and area of an
RPA is set out in BS5837:2012 Trees in relation to design, demolition, and
construction – Recommendations. A tree’s root system spreads far beyond
an RPA, often over 1.5 x the height of a tree and further. The plotting of
RPAs is a tool to help ensure a realistic amount of rooting medium is given
over to the tree to ensure its viability.
7.3 The British Standards provide recommendations to arboriculturists in the
basic position of RPAs, whilst relying on arboriculturists to use their
assessment of the site and knowledge of the tree system to modify the RPA
to better protect the tree’s future. The Standards recommend the RPA to be
drawn as a circle and then adapted should site conditions indicate
asymmetrical rooting (BS5837:2012 section 4.6.2).
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 14 of 22
7.4 Where RPAs are to be diminished or moved, an arboriculturist needs to
justify this using all their experience and tools reasonably available to them.
Suitable and useful mitigation needs to be made to ensure the health of the
tree.
7.5 It is my opinion that in a number of positions on the site, due regard for the
trees has not been sufficient to properly protect them. Relevant information
such as constraints on root growth has not been transferred from the Tree
Survey and Root Protection Area Drawing 3546.01 rev B to the Tree
Protection Plan 3546.16 Rev A.
7.6 In some cases RPAs have not been plotted correctly. Every RPA on the
Tree Survey and Root Protection Area Drawing is shown as a default circle.
This is so, even in the case of RPAs reaching into roads, buildings and
other structures that make normal rooting action exceptionally hard, if not
impossible.
7.7 6774, is a large ash tree on the south east of the site, figure 9. It is within
the hedgeline and is given a large RPA of 12 metres radius Map A shows
this tree, its crown and the RPA as plotted by the developers. Map B shows
where I would expect the trees RPA to be found. I have discounted the road
as part of the RPA and have spread the 452m2 required for the RPA to the
closest areas of good rooting medium.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 15 of 22
7.8 I do not consider a surfaced road to be suitable to add into an RPA. It is my
opinion that this area will be an exceptionally difficult area for a tree to
gather the nutrients, water and air needed for sustained tree growth.
7.9 During the planning application stage I wrote a letter to the LPA, dated 18th
September 2013, to express my concern about the poor plotting of the
RPAs within the TPP.
7.10 The LPA’s response of 26 September 2013 stated the Landscape
Development Section accepted the RPAs to be plotted correctly in tba’s
Tree Protection Plan 3546.16 Rev A.
7.11 This statement was backed up by tba in a letter, referenced
DRG/MEE/3536 on 6th November 2013. Much linespace is given to
explaining that roots are often found under roads, buildings and unsuitable
structures. I do not disagree with this, but an area such as a road cannot be
considered a usable area to put aside for the long term needs of a trees
rooting system. Trees will root into difficult areas, often in search of water,
nutrients and air. Below a road, if they manage to penetrate, roots quickly
exhaust these supplies and move on, often beyond the road and to better
rooting mediums. This is often shown by the lack of fine small, fibrous and
single celled roots found in mediums where rooting is difficult. The tree is
not gaining vitality from beneath the road, but extending its reach to better
areas where rooting is more profitable.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 16 of 22
7.12 I have shown in Map B where I consider the RPA of 6774 should lie and it
places constraints upon the design that the current TPP does not
recognise. The tree may be at risk of a severe restriction of resources
should the proposed plan go ahead. A mature and valuable tree such as
6774 should be allowed the maximum possible rooting area. A constricted
rooting area is liable to cause long term damage and loss of longevity to the
tree.
7.13 I have counted a total of 73 trees on the Tree Survey and Root Protection
Plan where the RPA has not been altered to better reflect current root
distribution.
7.14 A similar problem, with added difficulties, is found with tree 6809, figure 10.
This large twin-stemmed tree is a significant tree with a 950mm diameter at
breast height. It is scheduled for retention. The large bike shed next to the
tree where rooting will have been very poor is not shown on the TPP. I have
shown it on Map C, and similarly on Map D where I have redrawn the RPA
to show a better representation of where I would consider the RPA to be.
Additional constraints are placed on the development which is not
considered by the current planning proposal.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 17 of 22
7.15 Suggestion is made within the Arboricultural Impact Assessment (AIA) that
digging within the RPA is possible under the guidance of an arboriculturist
by hand tools and with an air spade that uses high pressure air to displace
soil. This is a common practice and considered to be of low impact to the
tree roots involved.
7.16 Section 4.2 of the AIA states that within the RPA, a line should be dug
where construction should happen. Any roots encountered below 25mm in
diameter should be neatly severed and any root over 25mm should be
‘redirected away from the development’.
7.17 No method statement is provided to suggest how tree roots over 25mm in
diameter can be redirected away from a development. When considering
the small amount of flex within a tree root of 25mm or above, I do not think
this is possible and the root is likely to snap or delaminate.
7.18 Any building work within an RPA requires significant justification and
remedial work. If the justification is acceptable and the tree is given the
space, remedial action is sufficient to ensure the tree survives in the long
term, then the damage done in the RPA is justified. There is no given
justification for the intrusion into the RPA of 6809 and no method statement
given on how this process will occur.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 18 of 22
7.19 In the case of tree 6809, not only is the RPA dug into, but a footpath laid
upon it as well. The footpath is to be laid over a cellular confinement
system, preventing compaction of soil around the roots below, but invariably
adding to the stress upon the tree to a further margin as already made by
the digging out of some of the tree’s RPA.
8.0 My findings – Professional approach to the deve lopment
8.1 I am concerned that there have been a number of deviations from
professional arboricultural good practice.
8.2 I have already stated, in section 7, findings where root protection areas
(RPAs) are not drawn correctly and where work within RPAs has been
specified but suitable mitigation has not been planned and unrealistic
operations specified.
8.3 I am concerned that the council officers of Newcastle-under-Lyme Borough
Council, who supported the scheme, did not subject the application to
thorough consideration and unbiased opinion.
8.4 I have already stated that after I questioned the shape of the RPAs in my
letter of 18th September, the Landscape Development Section dismissed
my claim stating the RPAs to be correct. In a previous application on the
same site 10/00531/FUL by the same applicant, the same Landscape
Development Officer requested that RPAs be moved off roads and included
into better rooting areas. This was requested for trees 6687-6690 on Station
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 19 of 22
Road and 6787-6802 on Quarry Bank Road, just 20 metres away from
6774. No justification for this change of opinion can be found.
8.5 As already discussed, areas of visually prominent, mature and amenable
trees are to be lost in a historical parkland landscape. The LPA is usually
opposed to substantial tree loss on development land, especially in the
case of visually prominent mature trees of high amenity value.
8.6 As already discussed, section 4.2 of the supplied Arboricultural Impact
Assessment (AIA) indicated that where RPAs are to be dug into to provide
foundations for roadways, then small roots (<25mm) can be cleanly cut and
larger roots are to be redirected back away from the construction zone,
where practical to do so.
8.7 No method statement is given on how to carry this out. I have never heard
of this practice before in 10 years of arboricultural work. I cannot see how it
could work. A root over 25mm in diameter is stiff and relatively brittle,
comparable to a branch of similar diameter. To bend it, would more likely
than not, break it. To suggest roots can be re-directed away from a
construction zone would require the tree roots to be much more flexible
than the average tree root of this size.
8.8 Section 4.3 of the AIA states a tree in G29 will have its RPA encroached
using the same methodology in section 4.2 of the AIA. No mitigation is
given for this operation which appears to be at odds with current standards.
The outcome of this will be that the tree roots, of whatever size, are likely to
be severed to the tree’s detriment.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 20 of 22
8.9 Some houses are in close proximity to trees, for example, the crown of
6808 overhangs the proposed house to the north of it at 5.25 metres away,
figure 11. Residents of such a property are liable to be concerned as to the
presence of a 17 metres high (and liable to grow much taller) tree
overshadowing their property. A similar problem is found with 6758 which
will be 6 metres from a house. At 18 metres this pine is likely to cause
distress to the property resident in high winds due to the shape of its crown.
Should the development happen, there will be a lot of pressure from
homeowners to remove a number of trees that cause concern because the
houses have been built too close to them.
8.10 Mitigation for the loss of the 151 trees on site is given in tba’s letter of 6th
November 2013. It states that 115 trees are to be planted. There are just a
few places within the proposed development where trees that will grow to a
large size can be planted and have a reasonable chance of growing to
maturity. To grow to maturity an English oak requires 20 metres of space
for the diameter of its crown. A small leaved lime would require 16 metres.
The quantity of housing on the site does not give space for the replacement
of large trees and it is unlikely that new residents will wish to see trees that
grow to a large size in close proximity to the house.
8.11 It is very unlikely that there will be space or residential support to allow
trees to be planted and reach such a size as to replace the amenity lost
should the development take place.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 21 of 22
9.0 Conclusion
9.1 The site has 306 trees that are mainly mature. I consider them to have a
high amenity value.
9.2 151 trees are set to be removed, half of the tree cover for the area.
9.3 Tree loss will have a varying effect on amenity depending on where the site
it viewed from. Some views will see very little amenity loss but others will
have severe losses. Overall, I would class the loss of the trees as a large
loss to amenity.
9.4 The proposal shows every root protection area (RPA) as a circle. Current
site conditions have not been considered and the RPAs have not been
made to better protect the trees by providing adequate rooting area. I have
counted 73 trees where this is an issue.
9.5 The use of root digging within RPAs in five instances is given no justification
and in some cases, because of the issues raised in 9.5, an adequate
amount of root protection is not afforded to the trees. There is no mitigation
prescribed to offset the damage done by digging within an RPA.
9.6 Unreasonable and unattainable methods are prescribed to redirect roots
away from construction areas.
Keele Parish Council, Arboricultural report DB/1
David Bailey The Hawthorns 27th November 2014 Page 22 of 22
9.7 It would appear the LPA failed to maintain standards whilst offering little
resistance to major amenity loss and questionable arboricultural practice.
9.8 The close proximity of some of the trees to households is liable to create
post-development pressure for tree removal.
9.9 The replanting plan of 115 trees is inadequate to replace the 151 mature
trees lost.
9.10 There is not enough space to replace the lost trees with similar sized trees.
9.11 If the plan should go ahead the tree loss to the area is liable to be
permanent.
9.12 I would agree with the decision of the LPA’s Planning Committee in refusing
permission for the proposed development and would support the refusal of
an appeal by the Planning Inspectorate on arboricultural grounds.