The following response was prepared by Tricia Marcouse on behalf of the Reading Urban Wildlife Group (RUWG) and Econet and has been submitted to Reading Borough Council.

Reading Borough Council - Draft Tree Strategy for Reading

From Reading Urban Wildlife Group, on behalf of RUWG and the groups represented by Econet. This consultation was sent to Econet members for comment before the final version was produced by RUWG.

Dear Sirs

We have commented on the policies in section 7 and 8 of the draft strategy below.

There are a few general points to start with.

Relevance to climate change mitigation
Trees are a good mitigation for the effects of climate change, but other policies would be far more effective for, perhaps, less cost. The requirement to increase tree cover in areas with little existing cover may be a more expensive policy than to increase tree cover in areas with quite a lot of trees already. Overall mitigation to climate impacts in the Borough would be increased with the latter policy as occasional tree planting is not likely to give a lot of local mitigation effect. It might be better to go for green wall approach and block planting areas in locations with limited tree cover at the moment than to consider introducing street trees. The number of street trees possible in a very built up area is unlikely to be very many, so the mitigation effect is very small.

Location of planting schemes and further maintenance
RUWG was responsible for Trees for Our Future campaign in Reading for the millennium. We identified locations for more trees in Reading, checked the location of all services and then got approval from the Council for the planting scheme and provided the Council with maps of each site showing the planting details so that ground maintenance contracts could be informed/changed. Our experience is as follows:

• It is very hard to find new locations for major tree planting that will not interfere with existing services. There needs to be a policy that looks at street/roundabout/open space tree provision in conjunction with major road works or major service change so that there is an opportunity to reroute some of the essential service provision. It is also necessary to extend the definition of trees to shrubs: there are many more options for shrub planting with reduced root runs than for trees, but the biodiversity, landscape value and some of the climate change elements are maintained
• The existing maintenance contracts in the town are a major problem for new tree planting and new planting is prone to strimmer attack and being mown off. There would be merit in planning new planting schemes for areas where the maintenance contract is up for review, and including the management requirements in the new contract. The contracts need to be supervised effectively.
• A lot of the soil structure is very damaged and not hospitable to tree growth; trees need a lot of support in the first years to overcome this problem (unless planted into block planting schemes where a larger area of soil can be improved)
• Industrial areas had a lot more opportunity for tree planting than urban streets, particularly as hedgelines along fences and within car parks. We suggest a good practice guidance note for estates and industry which would include the likely costs, the benefits, and the amount of space required. In general, industry needed a lot of convincing to provide areas for planting, but this could be a general policy for RBC and introduced at meetings for other planning purposes.

Staffing Needs and Planning the strategy
We believe that the staff in the Parks Department are quite well occupied at the moment. The strategy requires a lot of activities to be done "within existing staff and resources" and we are unconvinced that this is realistic with the timescales shown. We suggest two changes:

• The strategy objectives should have some priorities set now, not after the strategy is adopted and the consultation is over. It then needs a three year rolling programme making best use of available resources.
• The objective to survey and manage the tree stock and to have an effective input on planning and development policy requires trained staff. There should be a policy to employ more trained staff in this field and we suggest a new policy to employ an arboriculturalist to help drive this strategy forward, possibly sharing this new person with Wokingham BC to reduce financial impact.

Planning conditions/development briefs
We accept that a lot of the issues relating to trees is covered by the relevant BSs, such as 5837 and that developers should be following these requirements. The truth is that developers do NOT read the BS, and there should be some very clear guidelines provided, with pictures, together with planning conditions included as standard.

Veteran Trees
The enhanced biodiversity value of veteran trees is widely accepted. Unfortunately, it is these older trees that are most likely to have dead limbs with the potential to drop branches. They are therefore seen as more dangerous by the wider public.

The survey approach to existing tree stock should have a different approach to veteran trees with a greater emphasis on protection rather than felling and (we assume) replacement and/or extensive tree management to remove the rotten branches which have high conservation value for invertebrates and birds (and maybe bats). Obviously a risk assessment approach is needed in the urban context, and it maybe impossible to retain all of the top growth, but we think that there are often ways to mitigate risk of tree limbs falling on people, such as leaving the area under the canopy as unmanaged grassland so that people don't sit/play underneath or planting a protective ring of thorny shrub around the base. The policy should have a supposition AGAINST removal of veteran trees or their older growth.

Replacement planting
It isn't clear whether the policy is to plant new trees in advance of removal of older ones, or replacement after felling. We think the former policy should be adopted so that there is replacement in a new planting hole if possible and a continuation of tree cover in the street.

POLICY 7.1 Balance of Risk
The Tree Strategy mentions, often, both the benefits of trees in the urban landscape and the problems arising because of actual or perceived risk from urban trees and objections from the public concerning urban trees. The document says that there will be a risk assessment approach but, in our view, the document does not come to a conclusion about the priority of retaining or removing trees, but tries to document all of the opinions without coming to a conclusion. This would leave the decision concerning felling to individual opinions and open to persuasion by the last letter writer or telephone call. Inevitably, this is likely to be from people who want the tree removed, and not necessarily because of absolute risk but because of light, sap, whatever.

We therefore endorse Policy 7.1 on protection and retention of trees and would ask that this is NOT weakened by attempts to include "local opinion" as a reason for removal of urban trees.

We think the strategy should cross-reference the recent report Trees in Towns II.

"Although concerns about public safety will always restrict the number of mature and over-mature trees along roads and highways, policies for routine removal of all large trees during the early phases of maturity and their replacement with smaller, 'safer' alternatives should be challenged. The importance of mature and ancient trees in urban areas is undeniable and local authorities responsible for their management must balance public safety against their responsibilities for protecting and enhancing the environment. Decisions should be based on reasonable and realistic risk assessments, with the initial presumption being for protection of the tree, rather than removal. Local authorities need to act more proactively, with regular, professional tree inspections - prioritising street and roadside trees, and others in high-risk zones". Trees in Towns II, February 2008, Department for Communities and Local Government: London

POLICY 7.2, Management and Maintenance
We support 7.2.2, particularly the reference to green corridors (which RUWG has been promoting for decades).

7.2.3 is a nice idea, but it is not clear how the council can manage existing trees to maximise these benefits. We think you should expand this section because the only realistic thing to manage existing trees is to increase their robustness against increased drought/temperature/precipitation such as provide a better soil structure, more porous surface around them to increase water flow, and a policy for development.

7.2.4 yes, but the council should investigate as well whether such a wood station can take wood from gardens as well, or whether the council can offer a (paid for) service to householders for removal and reuse of timber and brash. It is not good practice for large amounts of wood to go into the composting schemes for green waste because it takes longer to break down in the compost cycle and then removes nitrogen from the soil once the compost is being used. Better to divert this to a wood station but retain the ability to monitor recycling and count towards council recycling targets.

Second point is that the location of the wood station should have a series of uses for the wood, which should include wood piles for wildlife. There needs to be sufficient storage for "useful" wood to be stored until needed.

Third point is to remember that there was government research some time ago into the use of brash piles for background heating of buildings; essentially the partial rotting of the pile of small diameter wood provided heat to the adjacent building. This should be considered when siting the wood station. Potentially it could heat the centre at Prospect Park or changing rooms in another open space area.

POLICY 7.3 Tree Planting
7.3.1 is fine, but 7.3.2 is much too negative, and the remainder of this policy section needs a practical guide as well as nice words. Yes, we agree that more trees is a good thing, and that the heavily built environment needs trees as well as the current "green" areas, but it is much more difficult to establish and maintain the trees in these areas. The council needs a proactive policy to increase its ability to plant trees in the less appropriate locations, even if this means a much higher cost/tree. It is pointless to have a general policy that "we need trees in the centre of towns" and then will end up saying "well, there's no point in planting trees in this area because they won't survive"

We have some suggested approaches, but this is an area that needs a lot more thought.

Planting strategies for new urban development or for replacement areas in hard landscape areas.
The problem is that planting is usually done as the end action, and isn't designed into the construction of the site. The general approach is to build the housing/office/whatever, then spread and compact whatever soil is available, lay the road surface, paving surface etc and THEN plant the tree in whatever soil is there. The planting hole may be large for the rootball, may have a planting medium installed, and there may be a porous surface on top of the planting hole, but this is still a planting pit within a hostile environment, prone to saturation in heavy precipitation and drought at other times, and with limited ability for the root system to develop in a radial manner. Often, the only uncompacted soil is along the drainlines, cable conduits etc where the soil has been disturbed and this encourages roots to grow along these lines, precisely where they are NOT wanted.

In Amsterdam they have a structured tree soil from a mixture of sharp sand and organic materials. This can be compacted to bear the load of car parking and pavements, but still has the right structure for tree roots. This encourages new planting in highly built environment to send roots out in all directions rather than down the drainlines and conduit lines which can be the only non-compacted soils available. This allows trees in parking areas or paved areas, taking up very limited space for maximum impact and without destruction of the solid surface. They also use root deflectors around new planting, particularly of larger (when mature) trees. These create a sort of horizontal flying saucer around the root ball when planted and promotes horizontal root development , preventing the sort of large prominent root systems around the base of trees that lift the pavement. Although roots might come back to the surface when past the deflector, it isn't so difficult to decide to prune these out as they are less structural for the tree than those immediately next to the bole.
(These techniques have been used in Poundbury by Duchy of Cornwall)

Deciding where to plant
Assuming a limit to tree planting each year, the plan for work should include the amount of time needed for weeding and watering etc in the first two years. Additional planting could take place where there are tree wardens or other tree carers.

Must it be TREES?? and single trees?
In the areas with very limited tree cover, there is often a high vandalism problem with new urban planting. This is partly use as football post, bad parking, and partly genuine vandalism. It could be much more appropriate to plant a block of woody shrubs, including some that are planned to grow to maturity. We recommend the planting block at the corner of Bath Road and Circuit Lane as a food model (planted by RBC around 1995ish I think). This was a very attractive shrubby planting when young, with a good variety of leaf colour and shape, and has survived whereas standards planted in the same grass area along the Bath Road were snapped off very quickly.

The understorey mix approach provides a lot more wildlife cover and food sources, so supports biodiversity.

The council should also look at green walls, particularly in the town centre where there is little space for urban trees. These will offer climate change mitigation, cooling systems for the town, wildlife options and a positive view. New developments should incorporate these, and retrofitting of existing buildings is possible.

Planning Guidance for new development
7.3.5 cross references planning policies, but we think that the tree strategy should include outline planning advice for the Borough to incorporate in these policies. Issues should include:

• Soil matrix for planting (as detailed above).
• Increasing amount of porous surfaces around trees to recharge groundwater.
• Priorities for retention of trees on development sites, accepting that not every tree can be saved. It is better to retain some trees than plan to keep all and KNOW that the trees cannot survive the development or will be shaded out by the new building.
• Protection of the identified trees from harm during development: parking of vehicles, storage of construction materials damaging soil structure, fencing against damage with boarding, not chestnut paling; drainage and service lines designed to be away from root structure.
• Replacement planting to enhance the biodiversity, which could be shrubs or hedging rather than one for one tree replacement.
• Use of native planting where appropriate.

As a conservation group, we would like ALL development to have the same attached conditions for tree conservation and replanting so that we could concentrate on discussing the specific landscape and biodiversity issues for each development rather than feeling that we should make the same comments each time about fencing, soil storage etc.

POLICY 8.1 Protect and Retain
If this tree strategy is to be effective, and you have the policy for more TPOs and more planting, then you can expect more people to undertake unauthorised pruning or removal of trees. We think you should expect to have to increase existing staff and resources to respond to this.

Protect existing trees, promote awareness and advice. This is going to be difficult to do with reduced resources for local government. Parks and Planning may not have the resources to do more than write the plan. Suggest that this is something that various charities might do for you, such as the woodland trust. Very important that RBC supports others to do this work, rather than necessarily taking the lead role.

Explore Tree Warden Scheme: Can this be done through Globe Groups to start with?

The one-stop-shop approach. Dedicated area of RBC website for trees. Again, this is something that existing personnel may not have time to do. There is a lot of information about trees on the web, the RBC website should link to these for background information, and then only needs to create the email contact, telephone numbers for advice line and ability to download the tree strategy and other RBC documents.