HomeMy WebLinkAbout2560383 - SubmissionKevin Dowds
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Sent: Wednesday 8 April 2026 19:28
To: Planning
Subject: Planning application 25/60383
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Attn :Brian Mc Geary
It is noted that the excavation works associated with this application are located wholly or partially
within the Root Protection Zone (RPZ) of the existing treeline along the site boundary. In
accordance with BS 5837:2012 — Trees in Relation to Design, Demolition and Construction, the
Root Protection Zone represents the minimum area around a tree required to safeguard essential
roots and soil structure that are critical to the tree's stability, vitality and long-term health. The
guidelines clearly state that excavation, soil disturbance and compaction within this zone should
be avoided, except in exceptional circumstances and only where fully justified and supported by
detailed arboricultural assessment and mitigation.
The works involving excavation within the RPZ is of particular concern, as root damage is often
non -visible at the time of construction, with impacts typically manifesting several years later in the
form of decline, instability, increased susceptibility to disease, or eventual tree failure. As such,
impacts on trees arising from RPZ encroachment are widely recognised as irreversible and
long-term, rather than short-term or temporary.
No evidence has been submitted to demonstrate that:
• the extent of excavation has avoided the RPZ to the greatest extent practicable;
• specialist arboricultural supervision was in place during excavation; or
• appropriate mitigation measures (such as no -dig construction techniques) were employed in
accordance with BS 5837:2012.
Furthermore, national and local planning practice recognises mature trees and established
treelines as important landscape and ecological assets, contributing to visual amenity,
biodiversity, microclimate regulation and environmental quality. Development that compromises
the health or structural integrity of such features conflicts with the proper planning and sustainable
development of the area.
In the absence of a robust Arboricultural Impact Assessment and Tree Protection Plan
demonstrating compliance with BS 5837:2012, it is considered that the excavation works within
the Root Protection Zone pose a significant risk to the long-term viability of the treeline.
In addition, the applicant's assertion that this issue is "a civil matter" is incorrect. While land
ownership disputes may fall under civil law, the protection of trees, hedgerows and boundary
vegetation affected by development is unequivocally a planning matter. The Planning Authority is
required to assess whether works have caused or will cause harm to retained trees, hedgerows,
or landscape features, regardless of ownership. Excavation within a Root Protection Zone,
alteration of an established boundary embankment, and any works with potential to compromise
tree stability or long-term viability fall squarely within the scope of planning control and BS
5837:2012. These impacts cannot be dismissed as a private dispute and must be fully assessed
as part of the planning decision.
I have attached photos here which clearly demonstrate the following impacts:
1. Excavation has taken place directly within the trees' root protection zones, removing supporting
soil and likely severing key roots.
2. The exposed bank shows active erosion, indicating ongoing loss of root -anchoring material.
3. Trees positioned immediately above the cut now face reduced stability and increased
windthrow risk.
4. Disturbance to the rooting environment will impair tree health and accelerate decline over
time.
5. These works conflict with BS 5837 guidance and represent a significant, avoidable impact on
retained trees.
Best wishes,
Phelim Mac ELWAIN
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