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Greening Blackpool consultation report

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February 2025

1.0   Introduction

1.1 This Consultation Report relates so the Greening Blackpool Supplementary Planning Document (SPD) and has been prepared in accordance with Regulation 12 of the Town and Country Planning (Local Development) (England) Regulations 2012.

1.2 The Council carried out a six-week comprehensive consultation on the Greening Blackpool SPD Consultation Draft between 17th December 2024 and 28th January 2025.

1.3 The Consultation Draft of the Greening Blackpool SPD was made available in accordance with the Regulations and the Council's adopted Statement of Community Involvement (September 2020).

1.4 Blackpool Council provided the opportunity for any organisations/individuals (including statutory bodies, key stakeholders and members of the public) to submit representations on the Consultation Draft by:

  • Publishing the Greening Blackpool SPD Draft on the Council's website
  • Notifying through letters and emails around 217 bodies, groups and individuals who had registered on the Council's consultation database (this includes specific and general consultation bodies as set out in the Regulations)

1.5 Appendices A, B and C provide evidence of the consultation undertaken for the Greening Blackpool SPD Consultation draft.

2.0  Overview of the consultation responses

2.1 The Council received 10 responses to the Greening Blackpool SPD Consultation Draft from statutory consultees, local planning agents and individual members of the public.

2.2 Table 1 below details the individuals and organisations that have submitted responses to the consultation, the representations they have made, and the Council's response. Some representations have resulted in the need to make minor modifications to the SPD text and this is also detailed in Table 1.

Table 1 - Representations received during consultation

Representations received
No.Name/CompanyType / Paragraph number /sectionSummary of commentsBlackpool Council response

01

Historic England

General Comment

Historic England has no comments to make on the content of the SPD

Comments noted.

02

Abbott Hull Associates

General Comments

The effort to refine planning policy and the opportunity to comment is welcomed.

Comment noted.

General Comments

The existing requirement is often not financially viable, particularly for conversion projects, and can hinder redevelopment efforts that would otherwise contribute to regeneration. The removal of the requirements for tree-planting for conversions is welcomed.

Comment noted.

General Comments

The requirement for tree-planting for new-build residential developments, holiday flats and holiday houses should be removed given the Government's introduction of statutory Biodiversity Net Gain (BNG) requirements.

Please see detailed response 3.2.

General Comments

The BNG requirements can place substantial pressure on development delivery and relaxing the tree-planting requirements would provide developers with greater flexibility.

Please see detailed response 3.2.

03

Boniface Architects (1)

General Comments

The principle behind the Greening Strategy is supported and the lack of greening and the benefits of greening are recognised.

Comments noted.

General Comments

The levy imposed through the Greening Strategy is stifling development as property values are insufficient to support them. The preparation of viability appraisals and legal agreements are further expense and delay. Construction costs have also risen. This is deterring investment in Blackpool.

These comments relate to the existing SPD but are noted.

04

Environment Agency

General Comment

The NPPF was updated in 2024. It should be ensured that the latest changes do not affect the requirements set out in the SPD. Wording should also be updated to reflect changes to NPPF paragraph numbers.

The updates to the NPPF in December 2024 are not considered to affect the requirements proposed in the new Greening Blackpool SPD.

Reference to NPPF and its paragraph numbers to be amended as appropriate in paras 3.1.1 to 3.1.4.3

05

Natural England

General Comments

Natural England does not have any specific comments on the Greening Blackpool SPD. Please refer to our advice regarding the Green Infrastructure Framework in Annex A.

Comment noted. No conflict with the Green Infrastructure Framework is identified.

General Comments

Advice is given with regard to Strategic Environmental Assessments and the requirements of the Habitats Regulations.

The SPD is not considered to require a Strategic Environmental Assessment or a Habitats Regulation Assessment.

06

Boniface Architects (2)

General Comments

It is very much welcomed that change of use applications will not be subject to contribution requirements.

Comment noted.

General Comments

The suggestion of a more focused on-site greening strategy through the planting of shrubs and/or hedgerow on site where possible makes far more sense as it would have a more immediate impact on the character of a streetscene.

Comment noted. 

07

Lindsay Oram (architect)

Para 4.9

The removal of the requirement for tree-planting for change of use proposals is welcomed.

Comment noted.

Para 4.9

Object to the extension of tree-planting requirements from 3 new-build dwellings to one or more. No justification has been provided. This change would negatively impact upon the viability of small developments.

Please see detailed response 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.9

The requirements for tree-planting in addition to statutory BNG requirements for 1 or 2 dwellings is unnecessary and overly onerous.

Please see detailed responses 3.2 and 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.8

Object to the requirement for trees to be planted in the ground and not in planters for the following reasons:

  • No justification has been provided.
  • The supporting text to Development Plan policies CS6 and DM21 supports planter use.
  • Use of tree planters has been accepted by the Planning Inspectorate.
  • The Council plants trees in planters where ground planting is not possible
  • Ground planting is not always possible due to proximity to services, easements, foundations etc
  • Planters can support biodiversity
  • It would be an unreasonable financial burden at odds with the Greening Strategy

Please see detailed response 3.4

General comments

The SPD requirements are too onerous in addition to statutory BNG requirements. Together they would affect the density of development and viability. Encouragement to provide tree planting where possible would be a more reasonable approach reflecting existing adopted policy.

Please see detailed response 3.2

General comments

The SPD should make it clear that tree planting will be taken into account and will count towards BNG provision.

Please see detailed response 3.2

Confirmation to be included

General comments

No timescale for use of financial contributions is specified in the SPD. Tree planting should be undertaken as early as possible and so a spending timescale of 5yrs should be specified. Further delay would not be justified.

This is a standard timeframe for planning obligations to be committed for use. It is considered that commitment for use is more appropriate than spend as it can be controlled and monitored by the Local Planning Authority. SPD to be amended accordingly to include an appropriate clarification.

General comments

The Council should support developers to 'green' developments as much as possible but not at the cost of restrictions or additional financial contributions.

Comments noted.

08

Fox Planning Consultancy

General comments

The Executive Committee report did not make clear the proposed changes and lacked explanation, justification and transparency. Any further consultation should include the changes highlighted.

Comments noted. Members were requested to consider the content of the proposed SPD and approve it for consultation. Members were provided with a summary document of the key changes and copies of both the existing and proposed SPD for review. There is no requirement for a track-change document to be provided and, given the extent of changes proposed, this option was considered to be inappropriate and unhelpful. The report to Executive Committee is considered to provide sufficient information to enable robust decision-making. No prejudice is identified.

General comment

It is unclear if Members are aware of the ramifications of central Government requirements relating to Biodiversity Net Gain provision, particularly with regard to any cumulative impact with Greening obligations

Comment noted. For the avoidance of any doubt, further explanation of statutory BNG can be included in the Executive report recommending adoption of the SPD.

General comment

The removal of the requirement for tree-planting for change of use proposals is welcomed.

Comments noted.

Para 4.9

Object to the extension of tree-planting requirements from 3 new-build dwellings to one or more. No justification has been provided. This change would negatively impact upon the viability of small developments.

Please see detailed response 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.9

The requirements for tree-planting in addition to statutory BNG requirements for 1 or 2 dwellings is unnecessary and overly onerous.

Please see detailed response 3.2 and 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.8

Object to the requirement for trees to be planted in the ground and not in planters for the following reasons:

  • No justification has been provided.
  • The supporting text to Development Plan policies CS6 and DM21 supports planter use.
  • Use of tree planters has been accepted by the Planning Inspectorate.
  • The Council plants trees in planters where ground planting is not possible
  • Ground planting is not always possible due to proximity to services, easements, foundations etc
  • Planters can support biodiversity
  • It would be an unreasonable financial burden at odds with the Greening Strategy

Please see detailed response 3.4

General comment

The SPD requirements are too onerous in addition to statutory BNG requirements. Together they would affect the density of development and viability. Encouragement to provide tree planting where possible would be a more reasonable approach reflecting existing adopted policy.

Please see detailed response 3.2

General comment

All applications should be treated equitably regardless of the identity of the applicant.

All applications are determined on their own merits. The identity of an applicant is not a relevant material planning consideration and is not a consideration afforded any weight.

General comment

The SPD should make it clear that tree planting will be taken into account and will count towards BNG provision.

Please see detailed response 3.2

Confirmation to be included

General comment

No timescale for use of financial contributions is specified in the SPD. Tree planting should be undertaken as early as possible and so a spending timescale of 5yrs should be specified. Further delay would not be justified.

This is a standard timeframe for planning obligations to be committed for use. It is considered that commitment for use is more appropriate than spend as it can be controlled and monitored by the Local Planning Authority. SPD to be amended accordingly to include an appropriate clarification.

General comment

The Council should support developers to 'green' developments as much as possible but not at the cost of restrictions or additional financial contributions.

Comments noted.

09

Gavin Harris

Para 4.9

The removal of the requirement for tree-planting for change of use proposals is welcomed.

Comments noted.

Para 4.9

Object to the extension of tree-planting requirements from 3 new-build dwellings to one or more. No justification has been provided. This change would negatively impact upon the viability of small developments.

Please see detailed response 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.9

The requirements for tree-planting in addition to statutory BNG requirements for 1 or 2 dwellings is unnecessary and overly onerous.

Please see detailed response 3.2 and 3.3. SPD amended to remove the requirement for schemes of 1 and 2 units within the Defined Inner Area to provide tree-planting.

Para 4.8

Object to the requirement for trees to be planted in the ground and not in planters for the following reasons:

  • No justification has been provided.
  • The supporting text to Development Plan policies CS6 and DM21 supports planter use.
  • Use of tree planters has been accepted by the Planning Inspectorate.
  • The Council plants trees in planters where ground planting is not possible
  • Ground planting is not always possible due to proximity to services, easements, foundations etc
  • Planters can support biodiversity
  • It would be an unreasonable financial burden at odds with the Greening Strategy

Please see detailed response 3.4

General comments

The SPD requirements are too onerous in addition to statutory BNG requirements. Together they would affect the density of development and viability. Encouragement to provide tree planting where possible would be a more reasonable approach reflecting existing adopted policy.

Please see detailed response 3.2

General comments

The SPD should make it clear that tree planting will be taken into account and will count towards BNG provision.

Please see detailed response 3.2

Confirmation to be included

General comments

No timescale for use of financial contributions is specified in the SPD. Tree planting should be undertaken as early as possible and so a spending timescale of 5yrs should be specified. Further delay would not be justified.

This is a standard timeframe for planning obligations to be committed for use. It is considered that commitment for use is more appropriate than spend as it can be controlled and monitored by the Local Planning Authority. SPD to be amended accordingly to include an appropriate clarification.

General comments

The Council should support developers to 'green' developments as much as possible but not at the cost of restrictions or additional financial contributions.

Comments noted.

10

United Utilities

General comments

Supportive of the principle of the document. Would highlight the benefit of early and constructive communication with UU and would encourage use of pre-application advice services.

Comments noted.

Para 4.6

Flexibility to allow for off-site provision is supported. On-site provision may not be the most appropriate long-term solution for the delivery of new green infrastructure to ensure that land around key UU infrastructure sites is not sterilised. New green infrastructure should not restrict potential future expansion or operation of UU infrastructure.

Comments noted.

Para 4.8

It is requested that the SPD states that trees should not be planted directly over water and wastewater assets or where excavation to reach the asset would require the removal of the tree / biodiversity.

This request can be incorporated into the SPD at para 4.8.

Para 5.6

It is requested that the wording is amended to read as follows:

  • Spaces for trees to reach maturity without causing nuisance or damage to structures or underground utilities services

This requested change can be incorporated into the SPD.

General comment

The link between green infrastructure and sustainable drainage is welcomed. Greening proposals should consider opportunities for surface water management and this should be from the outset of the design process. Multi-functional SUDS are advocated as an optimal solution.

Comments noted.

Para 4.14

It is requested that the wording is amended to read as follows:

Surface level car parking areas must have permeable surfaces and be well-screened, and landscaped with green infrastructure wherever possible, and be integrated with a strategy for surface water management.

This requested change can be incorporated into the SPD.

Para 5.11

It is requested that the wording is amended to read as follows:

Paragraph 182 of the National Planning Policy Framework is clear that applications which could affect drainage on or around the site should incorporate sustainable drainage systems which provide multi-functional benefits wherever possible. Applicants will be required to prioritise The council will encourage multi-functional SuDS features that include opportunities for landscaping, outdoor activities and play and which provide net gains in biodiversity, whilst helping to ensure local adaptation to climate change. Underground attenuation and flow control systems alone should only be considered on constrained sites where there are no opportunities to incorporate SuDS as green infrastructure. Where opportunities exist, the Council will expect require watercourses to be de-culverted where appropriate.

This requested change can be incorporated into the SPD.

3.0 Detailed responses to issues raised

3.1 Three key issues meriting closer consideration have been raised as a result of the consultation undertaken. Each will be considered in turn.

3.2 Overlap between Greening Blackpool obligations and statutory Biodiversity Net Gain (BNG) requirements

3.2.1 In February 2024, the government introduced statutory requirements for major-scale developments to deliver 10% BNG. This requirement was extended to minor-scale developments in April 2024. This requirement applies to all development proposals save for the following notable exceptions (those considered to be most relevant to Blackpool and this SPD):

  • Existing planning applications
  • Variations of existing planning permissions
  • Developments affecting a de minimis level of habitat (i.e. no important habitat and less than 5m linear or 25sqm area habitat)
  • Householder applications
  • Self-build and custom build applications

 3.2.2  Since the introduction of BNG, a significant amount of guidance has been published, both by government departments, advisory bodies and third parties. Initial understanding was that BNG requirements were additional to existing protections, statutory obligations and policy requirements. Within the Blackpool context, this was taken to mean that BNG requirements were to be additional to those generated by the Greening Blackpool SPD.

3.2.3 However, In March 2024 the government updated its guidance on "What you can count towards a development's biodiversity net gain". This guidance makes it clear that green infrastructure provision can count in full towards BNG provision. It is now understood that BNG requirements sit in addition to existing protections, obligations and requirements as they relate to biodiversity, such as those set out within the Habitats Regulations and the Wildlife and Countryside Act.

3.2.4 Consequently, paragraphs 4.7 and 4.8 of the proposed SPD have been updated to include confirmation that new on-site green infrastructure and tree provision can count towards BNG requirements. Replacement tree provision generally will not be counted towards BNG requirements and paragraph 4.6 has been amended to reflect this.

3.2.5 Some of the comments received have asserted that the Greening Blackpool SPD requirements should not apply to new-build schemes given the national BNG requirements. Two considerations are particularly relevant. Firstly, on-site greening and tree planting can count towards meeting a schemes BNG requirements as set out above. This removes any undue burden of both Greening Blackpool and BNG requirements applying. Secondly, Blackpool is a highly urbanised area where many potential development sites would not be subject to statutory BNG requirements because they do not include substantive habitat. Given the overwhelmingly lack of green infrastructure within central Blackpool (where such sites are most likely), it is considered essential that all opportunities for tree planting are pursued.

3.2.6 It should be noted that development viability is a material planning consideration. If it could be demonstrated through the submission of an open-book Financial Viability Appraisal that tree planting obligations would render a scheme financially unviable, this would be taken into account as part of the assessment of planning balance. Whilst some of the representations received have identified viability as a concern, none have provided substantive information or examples. Through the operation of the existing Greening Blackpool SPD to date, it has been conversion schemes, rather than new-build proposals, that have been most consistently cited as presenting a financial viability challenge.

3.2.7 On this basis, the application of tree-planting requirements to new build proposals is considered to be justified and should be retained.

3.3 Application of the tree planting requirements to new-build development proposals of 1 and 2 units

3.3.1 The Consultation Statement produced to support the consultation on the proposed Greening Blackpool SPD makes it clear under para 2.4 that substantive changes are proposed to the requirements for new tree planting for residential development. This is considered to be sufficient to draw interested parties' attention to this section of the document for review and comment.

3.3.2 It was proposed that the requirement for tree planting be extended to new-build proposals for 1 and 2 units to provide some mitigation against the loss of tree planting that will result from removing requirements from conversion schemes.

3.3.3 The considerations set out in paras 3.2.5 and 3.2.6 above apply equally to this issue.

3.3.4 However, it is accepted that the provision of trees on-site is particularly challenging within the Defined Inner Area where the redevelopment of existing properties is most beneficial to resort regeneration. As such it is now proposed that the extension of the tree planting requirement for new-build residential proposals be extended to schemes for 1 and 2 units outside of the Defined Inner Area only.

3.4  Use of planters

3.4.1 The new Greening Blackpool SPD as drafted stipulates that trees planted in planters cannot be counted towards tree planting requirements. This is because a relatively limited number of tree species adapt well to container planting. Planters can restrict root growth preventing development of a robust root system, and leave trees more vulnerable to temperature fluctuations which can cause stress.  This can stunt a tree's growth and overall health. Trees in containers require more intensive irrigation and fertilisation to maintain health. The size and type of planters required to sustain a tree, and the significant on-going maintenance requirements can often prove unviable, particularly for smaller schemes. Consequently, trees planted in planters generally have a shorter lifespan than those planted in the ground.

3.4.2 Objection has been raised against this stipulation on the basis that Local Plan Policies CS6 and DM21 are supportive of tree planting in containers. Whilst reference is made to container tree-planting in the supporting text to both policies, the contention that the proposed stipulation in the new SPD would be contrary to these policies is not agreed.

3.4.3 Core Strategy Policy CS6 relates to Green Infrastructure. No mention of planter use is made within the policy text. Supporting paragraph 5.94 highlights the need for green infrastructure given the intensely urban nature of the borough, and does acknowledge the constraints that exist and the need for innovative use of space. Supporting paragraphs 5.103 to 5.107 relate to the provision of new green infrastructure and paragraphs 5.109 and 5.110 in particular discuss provision within new developments. Paragraph 5.107 includes the only reference to planters when listing opportunities for urban greening which include "green alleyways, street trees and planters, allotments, woodland and community gardens as part of wider improvement initiatives". The clear inference is that planter use can be an effective option for the Council to introduce greening into existing public realm that otherwise does not offer any landscaping opportunities. There is no suggestion that planter use can be generally accepted as a substitution for traditional tree planting.

3.4.4 Policy DM21 of Local Plan Part 2 relates to Landscaping. Again, there is no reference to planter use within the wording of the policy. However, criteria 4 makes it clear that proposals for major developments and public spaces that would attract large crowds should include well designed hostile vehicle mitigation (HVM) measures. It states that HVM measures should be integrated sensitively and seamlessly into the townscape. The only reference to planter use within the supporting text to Policy DM21 is within paragraph 3.207. Here it states that planters can be an effective form of HVM that would be prioritised over more overtly defensive measures such as fixed bollards. Again there is no suggestion that planter use can be generally accepted as a substitution for traditional tree planting.

3.4.5 Policy CS6 expects all development to incorporate new or enhanced green infrastructure. It is clear that, where on-site provision is not possible, financial contributions will be sought to make appropriate provision for open space and green infrastructure. Policy DM21 stipulates that all developments are expected to contribute towards green and blue infrastructure. Criteria 1e sets out a specific requirement for development proposals to contribute towards tree planting in the town where appropriate.

3.4.6 It is considered that the proposed SPD addresses the aims and objectives of both policies by setting out requirements for public open space provision and tree planting from new developments. It is not considered that the general exclusion of tree planter use in lieu of traditional tree planting is contrary to the provisions of either policy. As such, no amendments to this stipulation are proposed.

Appendix A(b)

1.0 Reasons for amending the existing Greening Blackpool Supplementary Planning Document adopted May 2022

  • The council’s current Greening Blackpool SPD was adopted in May 2022
  • However, since adoption, the council has experienced a number of challenges in implementation. Regular planning agents working on behalf of developers have repeatedly commented that the requirements compromise the financial viability of development schemes. Numerous viability appraisals have been submitted to demonstrate this in respect of specific proposals. These have been considered either by independent consultants working on behalf of the council, or by experienced valuation surveyors employed within the council. In the majority of cases, it has been confirmed that the Greening Blackpool SPD requirements would either make the scheme unviable or marginally viable at best
  • Both the preparation of financial viability assessments and their review on behalf of the council incur costs, place further strain on resources and delay the determination of planning applications
  • In response to these issues, the council has undertaken a review of the implementation of the Greening Blackpool SPD to date. This review has found that some 54 applications have been liable for Greening Blackpool obligations in the two year period from 1 June 2022 to 31 May 2024. In total, these applications should have delivered around £960,000. However, between these dates only £58,000 was secured and, of this, only £16,000 has been paid. This clearly shows that the requirements of the SPD are compromising development deliverability
  • Parallel to these issues, Blackpool has seen a significant increase in the population of serviced self-contained holiday accommodation, both in the form of holiday flats and holiday houses. The Greening Blackpool SPD requirements for holiday and permanent accommodation are different, and this has also been a point of comment and concern for regular applicants and agents
  • The overwhelming need to green Blackpool and the multiple benefits that green infrastructure can provide are not disputed. However, there is an equally pressing need to ensure that Blackpool continues to attract growth and investment to deliver the town’s regeneration objectives and address long-standing issues relating to deprivation and poor-quality built form, particularly in our inner areas
  • As a result, the council has judged it appropriate to revise the Greening Blackpool SPD in order to strike a more workable balance to secure green infrastructure from development

2.0 Summary of main changes

2.1 Those familiar with the existing Greening Blackpool SPD will note that the proposed Greening Blackpool SPD is a much shorter document. The sections of supporting text have all been slimmed down to make the document as a whole more accessible and to focus on the most salient points. Biodiversity Net Gain, for example, is now a matter of national statute, and so a lengthy explanation of its merits is considered to be unnecessary. Discussion of protected species and protected landscapes has also been removed because these matters are not directly relevant to the requirements of the SPD, and because the relevant safeguards are well established in other legislation and policy. To further reduce the length of the document, and to reflect the way in which information is now presented on the council website, text duplicating relevant planning policies and sections of the national planning policy has been replaced by links to those documents.

2.2 As with the main body of the document, the appendices have also been rationalised. Appendix A of the existing SPD relates to supporting evidence which is available elsewhere on the council website as part of the evidence base to the local plan. Appendices B and D relate to national policy and legislation and biological heritage sites respectively. This information is also easily available elsewhere. Appendix E relates to submission requirements, but it is considered that this is adequately and more appropriately covered by the council’s published validation checklist.

2.3 Appendix C details trees and shrubs considered appropriate to the Blackpool area. This is useful information and the council recognises that it is used by applicants and agents. However, as our climate changes, this list is likewise likely to change. It is therefore considered more appropriate that this list be provided alongside rather than within the SPD, to enable it to be updated more easily and more frequently to reflect prevailing environmental conditions.

2.4 The key features of the requirements of the new SPD can be summarised as follows:

  • Biodiversity hierarchy – no substantive change from existing SPD - all development will be expected to demonstrate that the biodiversity hierarchy has been followed
  • Biodiversity net gain – no substantive change from existing SPD - all development must either comply with statutory biodiversity net gain requirements where they apply, or take full advantage of any opportunities to provide biodiversity net gain
  • Tree protection - no substantive change from existing SPD - it is expected that existing trees will be protected, and that any necessary loss of tree planting would be compensated for through replacement planting or payment of a tree contribution
  • New green infrastructure – new requirement - this is a new requirement that expects all developments to take the opportunities available to provide green infrastructure
  • New tree planting for residential uses – substantive change from existing SPD - this section stipulates the number of trees that different types of development would generate a requirement for. However, the requirement for new tree planting would no longer apply to change of use proposals
  • New tree planting for non-residential uses – substantive change from existing SPD - this section stipulates the number of trees that different types of development would generate a requirement for. However, the requirement for new tree planting would no longer apply to change of use proposals
  • Public open space (POS) – minor but no substantive change from existing SPD - this section now clarifies that POS contributions would only be required from developments for permanent residential uses. The amounts payable for the different sizes of dwelling have also been updated to reflect the information recorded by the 2021 Census

3.0 Justification for main changes

3.1 As set out in section 1, financial viability has proven to be a consistent challenge for developments liable for Greening Blackpool SPD obligations. In officer experience, this has most particularly been the case for change of use proposals and major scale schemes proposing a significant amount of floorspace.

3.2 Change of use applications may represent a relatively minor form of development, but they can have a very significant positive impact on the character and appearance of an area. This is certainly true within the defined Inner Area of the town where the redevelopment of a long-vacant property in a state of disrepair can lift the quality of a street, and often improve the quality of life for immediate neighbours who may have had to deal with issues of anti-social behaviour or structural decay.

3.3 The council wishes to encourage and support the redevelopment and regeneration of existing properties, and so considers it appropriate to remove the requirement for Greening Blackpool SPD obligations from change of use schemes. To help compensate for any loss of tree planting that would result, the proposed SPD would place greater emphasis on the provision of on-site greening. For example, within the densely developed inner areas of the town, the planting of a shrub or hedgerow at the front of a property would likely have a far more beneficial visual and greening impact than a tree planted off-site outside of the immediate streetscene.

3.4 It is proposed that new-build holiday accommodation continue to be liable for tree planting. This reflects the fact that holiday makers to the town benefit from the greening of the environment and also leave an environmental footprint that can be mitigated in part through provision of green infrastructure.

3.5 Holiday accommodation is not liable for public open space provision because, whilst some visitors may use local parks whilst in Blackpool, it is unlikely to be a main feature of their stay. Instead, public open space within the borough is considered to be most used and of most benefit to permanent residents.

3.6 It is recognised that financial viability may continue to be a challenge in some cases. However, the provision of financial viability appraisals as part of larger application submissions is anticipated to be less of a disproportionate burden for developers.

4.0 Next steps

4.1 The council will now consult on the proposed SPD for a period of 6 weeks. Once the consultation period has ended, the council will consider any comments made and may make amendments to the SPD if appropriate.

4.2 If no substantive objections are received to the proposed SPD, the council’s director of communications and regeneration has delegated authority to approve the SPD for adoption. If substantive objections are received, the SPD would have to be referred to the council’s executive committee for adoption.

4.2 The document will be available to view in the following locations:

  • Customer First reception, Corporation Street
  • Blackpool Central Library, Queen Street
  • Anchorsholme Library, Luton Road
  • Moor Park Library, Bristol Avenue
  • Boundary Library, Bathurst Avenue
  • Layton Library, Talbot Road
  • Revoe Library, Revoe Street
  • Palatine Library, St. Anne’s Road
  • Mereside Library, Langdale Place

4.3 The document will be available to view online

4.4 You can make comments by emailing planning@blackpool.gov.uk or via post to:

Planning department
PO Box 17
Corporation Street
Blackpool
FY1 1LZ

4.5 Comments can only be accepted in writing but, if you have any queries, you can call the development management duty line on 01253 476193.

4.6 Comments must be received by: 28 January 2025

Appendix B

Details of consultees
ConsulteesPlanning agents
  • Historic England
  • Natural England
  • Sport England
  • Forestry England
  • Homes England
  • Department for Environment, Food and Rural Affairs
  • Department for Transport
  • National Highways
  • Environment Agency
  • National Gas
  • Woodland Trust
  • Theatres Trust
  • Victorian Society
  • Twentieth Century Society
  • National Fire Protection Association
  • Campaign for the Protection of Rural England
  • Sustrans
  • Ministry of Defence
  • Civil Aviation Authority
  • Office for Rail and Road
  • Network Rail
  • Northern Railway
  • Marine Management Organisation
  • Coal Authority
  • National Grid
  • United Utilities PLC
  • Cadent Gas
  • Mobile UK Organisation
  • Lancashire County Council
  • Rossendale Borough Council
  • Fylde Borough Council
  • Pendle Borough Council
  • Wyre Borough Council
  • Staining Parish Council
  • St.Anne's-on-the-Sea Town Council
  • Westby Parish Council
  • Lancashire County Council Archaeological Advisory Service
  • Lancashire Wildlife Trust
  • Lancashire Police Crime Commissioner
  • Lancashire Minerals and Waste Framework (LCC)
  • Blackpool Bid
  • Marton Moss Neighbourhood Forum
  • Blackpool NHS Primary Care Trust
  • Blackpool NHS Clinical Commissioning Group
  • Blackpool Public Health
  • North West Ambulance Service
  • NHS Property Services
  • House Builders Federation
  • Design Council
  • Federation of Small Businesses (Blackpool)
  • CAMRA (Campaign for Real Ale)
  • Country Land and Business Association
  • Showmen's Guild
  • National Gypsy and Traveller Federation

(54 total)
  • DePol Associates
  • PWA Planning
  • Smith Love Planning Consultancy
  • Avison Young
  • Fish Associates
  • Harlequin Group
  • KR Cad Solutions
  • Clover Design
  • Fox Planning Consultancy
  • Davis Group
  • Abbott-Hull Associates
  • Fylde Design
  • Ben Jurin Architecture
  • Boniface Architects
  • G L Hearn
  • CFM Consultants
  • Firth Associates
  • Planning and Law
  • Eaglewood Design
  • AJUK
  • Keystone Design
  • DCMG Associates
  • Mellor Architects
  • Cassidy and Ashton
  • Gilling Dod
  • Hermolle Associates
  • RD Engineering
  • Planning By Design
  • CT Planning
  • JWPC Limited
  • WSP
  • Spawforths
  • Abbott  Associates
  • Planware
  • Lichfields
  • ELG Planning
  • DevPlan
  • JLL
  • Red Line Planning
  • Savills
  • Tetlow King
  • NJL Consulting
  • Steer Planning
  • James Scott Associates
  • WA Shipton Associates
  • Carters BC
  • Bramley Pate
  • Philip Lambert Architect
  • NTJ Design
  • RS Design
  • AD Consultancy
  • Lindsay Oram Architect
  • Chris Sinkinson
  • Dawn Hare
  • Peter Bryan
  • Richard Tatham
  • Jan Bargel
  • Lee Robert Fenton
  • Geoff Attwater
  • Ian Butler
  • Peter Ibbison
  • Robert Hopper
  • Keith Gleeson
  • Peter Redding
  • Bernard Bryze
  • AG EnergyCert
  • ADBS Ltd
  • JDT Sharples
  • Arch Design

(69 total)

In addition to the above, the following were notified:

  • 42 Local Ward Councillors
  • 52 Private Individuals or Interested Parties registered on the Council's Planning Consultation Register

Appendix C

Details of responders comments
Ref.RespondentNatureComments

1

Historic England

Statutory consultee

Historic England is the Government's statutory adviser on all matters relating to the historic environment in England. We are a non-departmental public body established under the National Heritage Act 1983 and sponsored by the Department for Culture, Media and Sport (DCMS). We champion and protect England's historic places, providing expert advice to local planning authorities, developers, owners and communities to help ensure our historic environment is properly understood, enjoyed and cared for.

Thank you for consulting Historic England on the above document. At this stage we have no comments to make on its content.

2

Abbott Hull Associates

Local Planning Agent

I would like to take this opportunity to thank the Local Planning Authority (LPA) for their continued efforts in developing and refining planning policies, and for opening this consultation to gather valuable feedback. The opportunity to contribute to the ongoing dialogue is greatly appreciated, and we welcome the chance to engage with the LPA to help shape policies that support both sustainable development and the practical needs of the development industry. We look forward to collaborating further to ensure that the policies are balanced, workable, and effective in achieving the shared goals for Blackpool's future.

The existing policy requiring tree planting for conversions is often not financially viable or practical due to several key constraints. Many of the buildings requiring conversion to be brought back into use are located in urban environments with limited space, where introducing tree planting is either impractical or impossible due to factors like small plots, dense development, or existing infrastructure. Additionally, the costs associated with retrofitting tree planting-such as redesigning site layouts, securing appropriate planting spaces and species, and ongoing maintenance-can be prohibitive for developers, particularly in projects with tight budgets or lower profit margins which is often the case in Blackpool due to low capital value and the increasing construction costs associated with refurbishment work.

In many cases, the primary objective of converting vacant or underused buildings is to bring them back into productive use quickly, contributing to regeneration and the efficient use of existing resources. Requiring tree planting in such scenarios adds unnecessary complexity and financial burden that can hinder redevelopment efforts. The removal of this requirement would allow developers to focus on maximising the potential of the building and site, promoting sustainable reuse without compromising the viability of the project.

I would like to propose further alterations to the policy to include the removal of tree planting requirements for new-build residential (C3) developments, holiday houses and holiday flats, particularly in light of the introduction of the Biodiversity Net Gain (BNG) policy. While the intent behind BNG is commendable, it has introduced significant challenges for developers, designers, and Local Planning Authorities (LPAs) alike. The need to achieve a measurable net gain in biodiversity often requires developers to take on complex, resource-intensive strategies that go beyond typical landscape requirements, such as creating or enhancing habitats, managing green spaces, and addressing ecological impacts.

These requirements, while essential for biodiversity conservation, can place substantial pressure on development timelines, costs, and the practical feasibility of projects. In many cases, the land available for new residential developments is limited, with tight site constraints that may not easily accommodate the necessary green infrastructure or tree planting without significantly impacting the scale and affordability of the project.

Relaxing tree planting requirements in the context of new builds would provide developers with greater flexibility in meeting the BNG targets while still contributing positively to the local environment. By allowing alternative approaches, such as off-site biodiversity enhancements or the integration of other forms of green infrastructure, this alteration would help balance the dual objectives of promoting biodiversity and facilitating the delivery of much-needed housing. This flexibility would support the successful implementation of BNG, while easing the challenges faced by developers and LPAs in meeting both environmental and housing delivery goals.

In summary, I welcome the removal of the requirement to provide tree planting for conversions and believe it to be a positive and pragmatic step that will encourage the reuse and redevelopment of existing vacant buildings. This change recognises the unique challenges of working with older structures, where space and design constraints may limit the feasibility of planting new trees. By focusing on the adaptive reuse of vacant buildings, this approach supports sustainable development, reduces pressure on greenfield sites, and helps bring underutilised properties back into productive use. This policy adjustment will facilitate more viable and efficient conversions, ensuring that redevelopment projects can proceed with greater flexibility while still contributing to the overall regeneration of Blackpool and the Council's aspirations for the town.

Finally, I kindly request that my thoughts regarding the removal of tree planting requirements for new-build residential (C3) developments, holiday houses and holiday flats, be considered further in the context of the revised policy. Given the challenges presented by the introduction of the BNG policy, I believe that additional flexibility in this area could help balance the need for biodiversity enhancement with the practical realities of development. I appreciate the opportunity to provide input and hope that these considerations will be taken into account as the policy is finalised.

3

Boniface Architects

Local Planning Agent

Thank you for the opportunity to comment on the above; I write in response to this from a first-hand point of view.

Firstly, the principle behind the Greening Strategy I support. Having grown up in Blackpool and living and working in the town, it is evident how little greening there is, particularly within the town centre. On a recent visit to Preston, I walked up Fishergate in the autumn which has been turned into an avenue with trees both sides of the high street. It is such a pleasant place to walk and I couldn't help think of our own high streets, particularly Church Street from the Winter Gardens down to the Grand Theatre, Victoria Street and Bank Hey Street and how little (or none-existent) the presence of any greenery is in these locations and how they, and the businesses would benefit from it.

However, it is my opinion, and the opinion of some of our clients and potential clients that the levy imposed through the Greening Strategy on potential projects is stifling development in the town to such a degree that we have lost work as a direct result of the levy. Unfortunately, the property values, once purchase costs and development costs have been taken into account are just not always there to warrant such a levy. I appreciate through viability appraisals that these are sometimes reduced but there is still the intial cost to some of our clients for the viability assessment and then the legal costs of the S106 aggrements, along with the delay this can incur. As you'll be aware, construction costs have risen sharply over the past few years and this is making current and future development even more expensive; the prospect of a further levy through the Greening Strategy is simply putting some of our clients off at the outset who then invest in other parts of the UK.

Blackpool needs private investment. It is great to see public investment and I look forward to seeing the face of our town continue to change but there has to be a different approach to go some way to achieving what the Greening Strategy set out to do in the first place and I do not think, as would our Clients, that the current process is a sustainable way forward, it simply renders many projects unviable in the first instance, putting off potential investment for properties which desperately need it and stifles development within the town.

4

Environment Agency

Statutory consultee

Thank you for consulting us on the proposed amendments to the Greening Blackpool SPD. We wish to make the following comment:

Update to the National Planning Policy Framework

The NPPF was updated in 2024. We recommend ensuring the latest changes do not affect the requirements outlined in the SPD. The wording should also be updated to accommodate changes to NPPF paragraph numbers.

We have no further comments to make on the proposed amendments.

5

Natural England

Statutory consultee

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Our remit includes protected sites and landscapes, biodiversity, geodiversity, soils, protected species, landscape character, green infrastructure and access to and enjoyment of nature.

Natural England does not have any specific comments on the Greening Blackpool Supplementary Planning Document, please refer to our advice regarding the Green Infrastructure Framework in Annex A.

The lack of comment from Natural England should not be interpreted as a statement that there are no impacts on the natural environment. Other bodies and individuals may wish to make comments that might help the Local Planning Authority (LPA) to fully take account of any environmental risks and opportunities relating to this document.

Strategic Environmental Assessment/Habitats Regulations Assessment:

A SPD requires a Strategic Environmental Assessment only in exceptional circumstances as set out in the Planning Practice Guidance here. While SPDs are unlikely to give rise to likely significant effects on European Sites, they should be considered as a plan under the Habitats Regulations in the same way as any other plan or project. If your SPD requires a Strategic Environmental Assessment or Habitats Regulation Assessment, you are required to consult us at certain stages as set out in the Planning Practice Guidance.

If you disagree with our assessment of this proposal as low risk, or should the proposal be amended in a way which significantly affects its impact on the natural environment, then in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, please consult Natural England again.

6

Boniface Architects (2)

Local Planning Agent

Further to my email below, dated 20th January 2025, I would like to take this opportunity to write in regards to the above in addition to my comments already submitted. My previous comments are perhaps more 'general' and I believe are still relevant with regards to environmental, economic and social aspects however I would like to take this opportunity to be more specific in relation to the draft SPD.

It is very much welcomed that Change of Use applications will not be subject to the contributions previously required as outlined within Section 4. It is my opinion, and that of some of our clients who invest within Blackpool that removing the contribution will encourage more investment, particularly within the inner areas and the suggestion of a more focused on-site greening strategy through the planting of shrubs and/or hedgerow on site where possible also makes far more sense in having a more immediate impact into the character of a streetscene.

7

Lindsay Oram

Local Planning Agent

SUPPORT - The clarification in paragraph 4.9 of the SPD stating that new tree planting is not required in the cases of change of use proposals is welcomed.  The previous interpretation of the SPD to require a financial contribution for tree planting for changes of use was unreasonable, unjustified and was proven upon appeal to be beyond the scope of the adopted SPD requirements. 

OBJECTION - I object to consultation draft SPD on the following grounds

AMENDMENT OF THRESHOLD FOR TREE PLANTING TO BE APPLIED TO ONE HOUSE AND MORE

Para 4.9 of the consultation draft SPD seeks to amend the current requirement for tree planting by extending the threshold from 3 dwelling to one dwelling or more. Therefore the proposed planting requirements are more onerous than the existing SPD and no justification has been provided.  The adopted policy with a threshold of 3 units ought to be retained in the interests of supporting the viability of small scale developments. The additional costs or financial contributions that the LPA is now attempting to introduce is likely to have a negative effect upon the viability of small developments. 

Furthermore, the majority of developments are now required by central government to provide BNG, including for a single house and therefore the above requirements are unnecessary and overly onerous. 

It is requested that the existing adopted threshold of 3 dwellings or more is retained. 

THE USE OF PLANTERS FOR TREE PLANTING

Local Plan Policy DM21 Landscaping supports the use of planters in its justification text. 

Core Strategy Policy CS6 Green Infrastructure, para 5.107, sets out opportunities for maximising urban greening and specifically supports the use of planters. 

Para 4.8 of the Greening consultation draft SPD states that "All trees must be planted in the ground and not in planters…."  

However, this is at odds with Policy DM21 and Policy CS6 which support the use of planters and do not preclude the use of planters for trees. Therefore, the consultation draft SPD potentially conflicts with adopted policy.  No justification has been provided for refusing to accept trees in planters as a greening contribution.  

It is submitted that this proposed amendment to the SPD is unreasonable as trees in planters have been accepted by the Planning Inspectorate in various recent planning appeal decisions as an acceptable form of planting/greening. 

Furthermore, local authorities plant trees in planters in hard surfaces areas, including car parks, to provide visual enhancements where planting in the ground is not possible.  It is inconsistent to support the siting of trees in planters by the council but not by applicants/developers. Taking into account the hard landscaped nature of many areas in Blackpool together with the policy objective of encouraging tree planting and biodiversity in general, the refusal to accept trees in planters is at odds with the greening strategy and would unreasonably increase the financial contributions payable by developers/applicants. 

It is submitted that the draft SPD is too onerous and unreasonable in terms the discouragement to provide planters where trees planted in the ground would not possible for various reasons including proximity to services, easements, foundations etc.  

It is requested that the proposed restriction to prevent the use of planters for trees is removed from the SPD in the interests of supporting biodiversity in all areas. 

OVERLAP WITH BNG PROVISION

The SPD requirements for planting should not be double counted to require both the Greening tree planting and BNG.  This would be too onerous on most developments.  It could also significantly affect the density of developments and viability. However an encouragement to provide higher levels of tree planting, where possible, would perhaps represent a more reasonable approach and reflect existing adopted policy. 

It is requested that clarification is added to the SPD to confirm that BNG provision will take into account tree planting provision required under the Greening SPD and that Greening SPD tree planting requirements will count towards BNG provision. 

THE TIMESCALE FOR GREENING BLACKPOOL

The SPD seeks financial contributions for additional tree planting. No mention is mad rod the timescale by which the council will use the financial contributions to implement tree planting.  In the interests of greening Blackpool and the perception of climate change it is submitted that tree planting  ought to be undertaken as early as possible and there is no justification for a delay. Therefore it is requested that the timescale for the council's spending of financial contributions is set at 5 years.  

CONCLUSION

In the current climate where the viability of most developments is affected by central government's requirements for BNG it appears unreasonable that the Council would now seek to introduce additional restrictions and financial burdens upon developments, particularly smaller developments. 

The introduction of additional financial burdens upon developers should be avoided. Rather the Council should be supportive of working with developers to "green" developments as much as possible but not at the cost of introducing restrictions or additional financial contributions. 

The LPA has not justified the additional burdens it is seeking to impose on de elopers/applicants. 

8

Fox Planning Consultancy

Local Planning Agent

I have serious concerns regarding the manner in which the proposed amendments were presented to Members in the 9 December 2024 Executive Committee report and in the subsequent public consultation.  The report did not make clear the proposed amendments compared with the adopted SPG, it lacked explanation, justification and transparency.  It was presented in a way that made it difficult for Members and the public to understand the differences between the adopted and proposed SPG.  The report did not set out justification for the increased financial burdens being sought from developers within the amendments and justification was not provided.  It is not clear whether Members are aware of the ramifications relating to central government BNG burdens alongside the proposed Greening SPG amendments.  The planning department's approach to increase taxation upon developers without clearly explaining this to Members lacks transparency and raises questions of potential maladministration.

SUPPORT

The clarification in paragraph 4.9 of the draft SPD stating that new tree planting is not required in the cases of change of use proposals is welcomed.  The previous interpretation of the SPD to require a financial contribution for tree planting for changes of use was unreasonable, unjustified and was proven upon appeal to be beyond the scope of the adopted SPD requirements. 

OBJECTION

I object to consultation draft SPD on the following grounds:

AMENDMENT TO THRESHOLD FOR TREE PLANTING TO BE APPLIED TO ONE HOUSE AND MORE

Para 4.9 of the consultation draft SPD seeks to amend the current requirement for tree planting by extending the threshold from 3 dwelling to one dwelling or more. Therefore the proposed planting requirements are more onerous than the existing SPD and no justification has been provided.  The adopted policy with a threshold of 3 units ought to be retained in the interests of supporting the viability of small scale developments.  The additional costs or financial contributions that the LPA is now attempting to introduce is likely to have a negative effect upon the viability of small developments. 

Furthermore, the majority of developments are now required  by central government to provide BNG, including for a single house and therefore the above requirements are unnecessary and overly onerous. 

It is requested that the existing adopted threshold of 3 dwellings or more is retained. 

 

THE USE OF PLANTERS FOR TREE PLANTING

Local Plan Policy DM21 Landscaping supports the use of planters in its justification text. 

Core Strategy Policy CS6 Green Infrastructure, para 5.107, sets out opportunities for maximising urban greening and specifically supports the use of planters. 

Para 4.8 of the Greening consultation draft SPD states that "All trees must be planted in the ground and not in planters…."  

However, this is at odds with Policy DM21 and Policy CS6 which support the use of planters and do not preclude the use of planters for trees. Therefore, the consultation draft SPD potentially conflicts with adopted policy.   No justification has been provided for refusing to accept trees in planters as a greening contribution.  

It is submitted that this proposed amendment to the SPD is  unreasonable as trees in planters have been accepted by the Planning Inspectorate in various recent planning appeal decisions  as an acceptable form of planting/greening. Sometimes this is the only option available and planters can make a positive contribution to urban geeening, particularly when opportunities for planting in the ground are not available  

Furthermore, local authorities plant trees in planters in hard surfaces areas, including car parks, to provide visual enhancements where planting in the ground is not possible.  It is inconsistent to support the siting of trees in planters by the council but not by applicants/developers. Taking into account the hard landscaped nature of many areas in Blackpool together with the policy objective of encouraging tree planting and biodiversity in general, across the whole of the Borough, an amended policy to accept trees in planters is at odds with the greening strategy and would unreasonably increase the financial contributions payable by developers/applicants. 

It is submitted that the draft SPD is too onerous and unreasonable in terms the discouragement to provide planters where trees planted in the ground would not possible for various reasons including proximity to services, easements, foundations etc.  

It is requested that the proposed restriction to prevent the use of planters for trees is removed from the SPD in the interests of supporting biodiversity in all areas. 

OVERLAP WITH BNG PROVISION

Policy DM21 was adopted before BNG requirements were brought out by central government  the extent of the BNG burden was  neither known or anticipated when DM21 was adopted  

The SPD requirements for planting should not be double counted to require both the greening tree planting and BNG on sites where this is not possible to achieve. This would be too onerous on most developments.  It could also significantly affect the density of developments and viability. However an encouragement to provide higher levels of tree planting, where possible, would perhaps represent a more reasonable approach and reflect existing adopted policy. 

The Council recently approved an application for the new court building where greening requirements were relaxed.  Council policy ought to be transparent and an inconsistency in the application of the policy that favours government developments but taxes private developments is unacceptable.  

It is requested that clarification is added to the SPD to confirm that BNG provision will take into account tree planting provision required under the Greening SPD and that Greening SPD tree planting requirements will count towards BNG provision.  

THE TIMESCALE FOR  GREENING BLACKPOOL

The SPD seeks financial contributions for additional tree planting. No mention is made of the timescale by which the council will use the financial contributions to implement tree planting.  In the interests of greening Blackpool and the perception of climate change it is submitted that tree planting  ought to be undertaken as early as possible and there is no justification for a delay. Therefore it is requested that the timescale for the council's spending of financial contributions is set at 5 years.  

The previously suggested period of 30 years is unreasonable and unacceptable  

CONCLUSION

The presentation of the proposed changes is not transparent and lacks explanation and justification. 

In the current climate where the viability of most developments is affected by central government's requirements for BNG it appears unreasonable and unjustified that the planning department would now seek to introduce additional restrictions and financial burdens upon developments, particularly smaller developments. 

The introduction of additional financial burdens upon developers should be avoided. Rather the Council should be supportive of working with developers to "green" developments as much as possible but not at the cost of introducing restrictions or additional financial contributions. 

The LPA has not justified the additional burdens it is seeking to impose on developers/applicants. The consultation paper does not make it clear the extent of the proposed changes compared with the existing SPD  

The requirement for the consultation and amendments to policy to be transparent including the reasons and justification for the proposed amendments ought to be properly set out for the public and Councillors to understand before any adoption of the amended policy takes place. The consultation has failed to set out the proposed changes and justification in a transparent manner. 

Additional taxation is being proposed without providing justification or explanation. 

The proposed approach to tax small developments is clearly not justified and Members/Councillors should be made aware of exactly what the planning department is asking them to support. 

In the event that any further consultation is undertaken please will you provide highlighted changes so that the proposed amendments are transparent and to save everyone having to read through the whole document. 

9

Gavin Harris

Interested party

SUPPORT - The clarification in paragraph 4.9 of the SPD stating that new tree planting is not required in the cases of change of use proposals is welcomed.  The previous interpretation of the SPD to require a financial contribution for tree planting for changes of use was unreasonable, unjustified and was proven upon appeal to be beyond the scope of the adopted SPD requirements. 

OBJECTION - I object to consultation draft SPD on the following grounds

AMENDMENT OF THRESHOLD FOR TREE PLANTING TO BE APPLIED TO ONE HOUSE AND MORE

Para 4.9 of the consultation draft SPD seeks to amend the current requirement for tree planting by extending the threshold from 3 dwelling to one dwelling or more. Therefore the proposed planting requirements are more onerous than the existing SPD and no justification has been provided.  The adopted policy with a threshold of 3 units ought to be retained in the interests of supporting the viability of small scale developments. The additional costs or financial contributions that the LPA is now attempting to introduce is likely to have a negative effect upon the viability of small developments. 

Furthermore, the majority of developments are now required by central government to provide BNG, including for a single house and therefore the above requirements are unnecessary and overly onerous. 

It is requested that the existing adopted threshold of 3 dwellings or more is retained. 

THE USE OF PLANTERS FOR TREE PLANTING

Local Plan Policy DM21 Landscaping supports the use of planters in its justification text. 

Core Strategy Policy CS6 Green Infrastructure, para 5.107, sets out opportunities for maximising urban greening and specifically supports the use of planters. 

Para 4.8 of the Greening consultation draft SPD states that "All trees must be planted in the ground and not in planters…."  

However, this is at odds with Policy DM21 and Policy CS6 which support the use of planters and do not preclude the use of planters for trees. Therefore, the consultation draft SPD potentially conflicts with adopted policy.  No justification has been provided for refusing to accept trees in planters as a greening contribution.  

It is submitted that this proposed amendment to the SPD is unreasonable as trees in planters have been accepted by the Planning Inspectorate in various recent planning appeal decisions as an acceptable form of planting/greening. 

Furthermore, local authorities plant trees in planters in hard surfaces areas, including car parks, to provide visual enhancements where planting in the ground is not possible.  It is inconsistent to support the siting of trees in planters by the council but not by applicants/developers. Taking into account the hard landscaped nature of many areas in Blackpool together with the policy objective of encouraging tree planting and biodiversity in general, the refusal to accept trees in planters is at odds with the greening strategy and would unreasonably increase the financial contributions payable by developers/applicants. 

It is submitted that the draft SPD is too onerous and unreasonable in terms the discouragement to provide planters where trees planted in the ground would not possible for various reasons including proximity to services, easements, foundations etc.  

It is requested that the proposed restriction to prevent the use of planters for trees is removed from the SPD in the interests of supporting biodiversity in all areas. 

OVERLAP WITH BNG PROVISION

The SPD requirements for planting should not be double counted to require both the Greening tree planting and BNG.  This would be too onerous on most developments.  It could also significantly affect the density of developments and viability. However an encouragement to provide higher levels of tree planting, where possible, would perhaps represent a more reasonable approach and reflect existing adopted policy. 

It is requested that clarification is added to the SPD to confirm that BNG provision will take into account tree planting provision required under the Greening SPD and that Greening SPD tree planting requirements will count towards BNG provision. 

THE TIMESCALE FOR GREENING BLACKPOOL

The SPD seeks financial contributions for additional tree planting. No mention is made for I the timescale by which the council will use the financial contributions to implement tree planting.  In the interests of greening Blackpool and the perception of climate change it is submitted that tree planting  ought to be undertaken as early as possible and there is no justification for a delay. Therefore it is requested that the timescale for the council's spending of financial contributions is set at 5 years.  

CONCLUSION

In the current climate where the viability of most developments is affected by central government's requirements for BNG it appears unreasonable that the Council would now seek to introduce additional restrictions and financial burdens upon developments, particularly smaller developments. 

The introduction of additional financial burdens upon developers should be avoided. Rather the Council should be supportive of working with developers to "green" developments as much as possible but not at the cost of introducing restrictions or additional financial contributions. 

The LPA has not justified the additional burdens it is seeking to impose on developers/applicants. 

10

United Utilities

Statutory consultee

Thank you for your consultation seeking the views of United Utilities Water Limited (UUW) as part of the modification to the Greening Blackpool Supplementary Planning Document ('the SPD'). We are supportive of the principle of preparing this document as we recognise the importance of delivering environmental and quality of life benefits for local communities.

UUW wishes to build a strong partnership with all local planning authorities (LPAs) to aid sustainable development and growth within its area of operation. We aim to proactively identify future development needs and share our information. This helps:

  • ensure a strong connection between development and infrastructure planning;
  • deliver sound planning strategies; and
  • inform our future infrastructure investment submissions for determination by our regulator.

UUW wishes to highlight the benefit of early, constructive communication with the Council and site promoters to ensure a co-ordinated approach to the delivery of sustainable growth in sustainable locations. New development should be focused in sustainable locations which are accessible to local services and infrastructure. We can most appropriately manage the impact of development on our infrastructure if development is identified in locations where infrastructure is available with existing capacity.

We encourage you to direct future developers to our pre-application service to discuss their schemes and highlight any potential issues by contacting:

Developer Services - Wastewater

Tel: 03456 723 723

Email: SewerAdoptions@uuplc.co.uk

Developer Services - Water

Tel: 0345 072 6067

Email: DeveloperServicesWater@uuplc.co.uk

  1. LANDSCAPING AND BIODIVERSITY

Tree Protection

We note section 4.6 that if it is not possible to provide replacement trees on site, alternative green infrastructure should be provided wherever practicable.

We support the flexibility within policy to allow for off-site provision. This is particularly in respect of existing and new infrastructure sites. In relation to existing and proposed utility infrastructure, we wish to highlight that on-site provision may not be the most appropriate long-term solution for the delivery of new green infrastructure. This is because it is critical that land around our key infrastructure sites is not sterilised. We are keen to ensure that any new green infrastructure does not restrict the potential future expansion and operation of utility infrastructure which may need to expand in the future.

 

This approach is supported by the Planning Practice Guidance (PPG) which states that the approach to BNG should be resilient to future pressures from further development. It states:

'When assessing opportunities and proposals to secure biodiversity net gain, the local planning authority will need to have regard to all relevant policies, especially those on open space, health, green infrastructure, Green Belt and landscape. It will also be important to consider whether provisions for biodiversity net gain will be resilient to future pressures from further development or climate change, and supported by appropriate maintenance arrangements.

Paragraph: 023 reference ID: 8-023-20190721

Revision date: 21 07 2019'

New tree planting (required in some cases)

Within section 4.8, we request that the SPD states that trees should not be planted directly over water and wastewater assets or where excavation onto the asset would require removal of the tree/ biodiversity.

The approach to any planting must have regard to the proximity to existing or proposed utility assets to ensure there is no impact on these assets. UUW wishes to note the importance of any approach to planting new trees and landscaping giving due consideration to the impact on utility services noting the implications that can arise as a result of planting too close to our assets. This can result in root ingress, which in turn increases the risk of drainage system failure and increases flood risk. Further details on suitable trees for planting near our assets can be found in our 'Standard Conditions for Works Adjacent to Pipelines' (Document Ref: 90048 Issue 3.1 July 2015). A copy of this document can be found on our website.

Trees and Hedgerows

Based on the information provided in the above section 'New tree planting (required in some cases)', UUW wishes to recommend that the wording of bullet point three in section 5.6 is amended to read as follows:

  • 'Spaces for trees to reach maturity without causing nuisance or damage to structures or underground utility services'

2. DRAINAGE AND SURFACE WATER MANAGEMENT

New green infrastructure (applicable in all cases)

United Utilities is supportive of the link you make between sustainable drainage and new green infrastructure in the draft SPD. It is critical that applicants consider how any proposals for development, including any public realm that is to be created, can be linked to opportunities for surface water management. Any landscaping and public realm improvements should evaluate opportunities for surface water management to include opportunities for source control and slowing the flow of surface water through the incorporation of blue and green infrastructure. It is preferable that the evaluation of surface water and flood risk management opportunities are undertaken at the outset of the design process. Such an approach has added benefits associated with the quality of the public realm, the enhancement of biodiversity and urban cooling.

As outlined in 'Building for a Healthy Life', we recommend that landscaping proposals are linked to surface water management in accordance with the 'four pillars' of sustainable drainage systems, i.e., water quantity, water quality, amenity and biodiversity. National policy is clear that priority should be given to multi-functional Sustainable Drainage System (SuDS) over traditional underground, tanked and piped storage systems. Sustainable water management, especially in the form of multi-functional SuDS, help us adapt and respond to the challenges posed by climate change and the impact of urbanising our environment. SuDS also have wider benefits and represent an opportunity to improve the quality of urban environments by changing 'grey' to 'green and blue' infrastructure. They can help to create more attractive and usable spaces which help with social cohesion by connecting people, improving amenity and wellbeing, and offering opportunities for nature. In our urban environments there are often areas that can be better used to manage rainfall run off through surface level SuDS which can transform grey and impermeable spaces to greener, more attractive and resilient spaces appreciated by the community.

We recommend that you refer to the Susdrain website which includes a range of case studies that show examples of how SuDS have been implemented in the urban environment.

Car parking

We wish to emphasise the evaluation of surface water management opportunities should be undertaken early in the design process. It is imperative that the approach to design including site analysis is intrinsically linked to 'making space for water'. Sustainable surface water management will be particularly important to consider in the context of car parking. Therefore, UUW wishes to recommend the following amended wording to the car parking section of 4.0:

'Surface level car parking areas must have permeable surfaces and be well-screened, and landscaped with green infrastructure wherever possible, and be integrated with a strategy for surface water management'.

Surface water management and drainage

Based on the information provided in the above section 'New green infrastructure (applicable in all cases)', we request that section 5.11 is amended to read as follows:

'5.11 Paragraph 182 of the National Planning Policy Framework is clear that applications which could affect drainage on or around the site should incorporate sustainable drainage systems which provide multi-functional benefits wherever possible. Applicants will be required to prioritise The council will encourage multi-functional SuDS features that include opportunities for landscaping, outdoor activities and play and which provide net gains in biodiversity, whilst helping to ensure local adaptation to climate change. Underground attenuation and flow control systems alone should only be considered on constrained sites where there are no opportunities to incorporate SuDS as green infrastructure. Where opportunities exist, the Council will expect require watercourses to be de-culverted where appropriate.'

Moving forward, we respectfully request that the Council continues to consult with UUW for all future planning documents. In the meantime, if you have any queries or would like to discuss this representation, please do not hesitate to contact me at planning.liaison@uuplc.co.uk.

 

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