Why trees keep drawing the short straw in the new nature rules

We’ve written before about the rule change that, from 6 August 2026, lets the smallest building sites skip the ‘leave nature better off’ requirement. But that small-sites exemption is only one of several changes on the way to the same set of nature rules. Taken together, they keep landing on the same casualty: the everyday trees growing on our streets, and in our parks and gardens.

Here is why trees, in particular, keep losing out.

Trees are the odd one out

Most habitats the BNG rules deal with — grassland, scrub, hedgerows etc. — can, in principle, be recreated somewhere else within a few years.

Plant a replacement tree for one felled and it starts life as a sapling and will take (assuming it lives long enough) years to do what the felled tree was already doing: a mature tree takes decades to mature and at least nine saplings to replace just one. The largest trees would need at least 19 new trees and still take many years to ‘replace’.

And a tree’s real value — the shade and cleaner air it provides us, soaking up rainfall, its character and the nature it shelters that you see daily — is delivered exactly where it stands. Move the ‘replacement’ to a distant field few will ever visit and, while you may have ‘ticked the replacement box’, you have lost the thing that mattered – your local, everyday tree.

That is the backdrop to the changes now coming.

Clearing trees here, ‘making up for it’ miles away

For slightly larger sites, one proposal would let developers skip trying to keep trees on the site and instead allow them to pay for replacement habitat (not necessarily trees) somewhere else — potentially a long way off. The mature tree that was growing near you, ‘replaced’ by a patch of new grassland or scrub far away in some ‘foreign field’ you cannot visit. The paperwork balances but your tree is gone.

A much bigger exemption for brownfield sites

This could be the big one for towns and cities. The Government has floated exempting brownfield sites of up to 2.5 hectares — more than ten times the size of the small-sites limit. Brownfield and urban plots are exactly where many mature street trees grow, so an exemption on that scale could wave through a lot of tree loss. It is still just a proposal and a final decision is awaited, but the threat is real.

‘Temporary’ felling that lasts forever

Another idea would exempt “temporary” development — anything that can put back within five years. That may be fine for many habitats, but not for trees: you cannot regrow a mature tree in five years. Fell it for a short-term purpose and it is gone for good.

Trees removed in the name of nature

One proposed exemption covers work to improve parks, playing fields and public gardens, or projects whose main aim is to help wildlife. Well meant — but these are often the places where big, mature trees grow. If the ‘improvement’ means cutting trees down — for example, to create open grassland or a play space — there would be no obligation to plant replacements.

Why it adds up

On their own, each of these is a small technical tweak. Together, they push in one direction: it becomes easier to remove the trees closest to where people live, and to offset them — if at all — with habitat elsewhere. The result, over time, is fewer trees in our neighbourhoods and the inevitable ‘greying’ of our urban spaces.

The older protections for trees still stand — Tree Preservation Orders, conservation-area rules, and protection for ancient and veteran trees — along with any local tree protection policies your council has adopted, but these are not always fully applied. Even so, this is exactly why these protections will matter more than ever.


Read the full briefing note here

Our earlier companion post is also available here – The small-sites rule change that could quietly cost your neighbourhood its trees

The small-sites rule change that could quietly cost your neighbourhood its trees

From 6 August 2026, a change to the planning rules takes effect that most people will never hear about — but it could reshape the trees on our streets, in our gardens and on the small plots being built on all over the country.

Here is the short version.

What is changing

When land is developed, the law has, since 2024, usually required a small boost to nature — a “Biodiversity Net Gain” of at least 10%. In plain terms, a development is meant to leave nature a little better off than it found it.

From 6 August, the smallest sites — those of 0.2 hectares or less (about 2,000 square metres, roughly a third of a football pitch, or a small cluster of houses and their gardens) — no longer have to do this at all.

For hard-pressed small builders, that is a welcome simplification. But there is a catch for trees.

Why trees are caught in the middle

Under the old rules, removing even a single tree was usually enough to bring a small project into the nature-boost system — because of the way a tree’s protected “footprint” is measured. In practice, that meant a developer could not quietly fell a tree on a small plot without having to make good the loss.

The new rule swaps that “what is the impact?” test for a much simpler “how big is the site?” test. If the site is 0.2 hectares or smaller, the nature rules simply do not apply — however many trees are cleared.

What that means on the ground

On a site right at the new limit, the equivalent of up to 48 small trees — or around a dozen mature ones — could be removed with no requirement to replace or compensate for them under this system. And the trees most exposed are exactly the ones we tend to notice most: established trees on small urban and infill plots.

What still protects trees

It is not a free-for-all. Tree Preservation Orders, conservation-area rules and the special protections for ancient and veteran trees all still apply — they sit entirely outside this change. Some councils also have their own local tree policies: Bristol’s Tree Replacement Standard, for example, still requires replacement planting whatever the new exemption says.

The snag is that these local protections only exist where a council has actually put them in place — and not every council has.

Why it matters

The change is a sensible piece of red-tape reduction for small builders. But it is also, almost by accident, a real step back for the everyday trees that give our neighbourhoods shade, character and wildlife. From August, whether the trees near you are protected will depend less on national nature rules and more on whether your council has its own policies — and on whether a particular tree happens to be covered by an order.

If you value the trees around you, it is worth asking your local council what protections are in place.


We have set out the full detail — the mechanics, the legal position, and what to watch next — in an accompanying briefing note.

Read the full briefing note here.

St Philip’s Marsh: do the green space sums add up?

Bristol’s biggest regeneration plan promises parks within a five-minute walk of every front door. We measured the plan’s own drawings to see whether the promise holds. Here’s what we found.

St Philip’s Marsh is about to become the new place in Bristol to live, work and study. The draft Masterplan, created by the Bristol Temple Quarter Partnership is now out for consultation. It proposes at least 7,000 homes — for roughly 15,000 people — on 94 hectares of old industrial land east of Temple Meads, plus workspace for thousands of jobs and student housing beside the university’s new campus. For an area with almost no publicly accessible green space currently, the Masterplan’s vision of parks, green streets and riverside walks is most welcome, and we want it to succeed.

However, when we measured the plan’s own drawings — every park, square and green corridor, checked against the Council’s own GIS records — the numbers put forward started to wobble.


A table that vanished

The Masterplan’s headline is 22.4 hectares of open space and green corridors, including 8.1 hectares of ‘new open space’. Curiously, the published figure that should show this breakdown contains no numbers at all. The arithmetic survives only in the figure’s hidden accessibility text — the description read aloud by screen readers. This refers to a quantification table ‘overlaid on the side of the plan’. However, this table was removed before publication, and nobody has updated the hidden text. Our own measurements confirm the totals are correctly computed. So why take the table out?


How big is Sparke Evans Park? Pick a number

The document gives three different sizes for the area’s only existing park, Sparke Evans Park: 2.9 hectares in the body text, 2.5 in the hidden arithmetic, and 2.34 as drawn. The Council’s own GIS records 2.3416 ha. A small thing, perhaps — but the body text overstates the park by 24%, which is the baseline everything else is measured from.

A bigger question is how large is the site itself? The Masterplan never says. Its drawn boundary encloses 94 hectares but the council’s investment website says St Philip’s Marsh totals 65 hectares. Nobody reconciles the two. This is important as the site area is the denominator for the plan’s flagship promise of 25% tree canopy. 25% of which number?


What actually counts as a park?

Bristol’s Parks and Green Spaces Strategy is clear that ‘public realm’ — squares, promenades, landscaped frontages — does not count as open space for recreation. Strip those out of the Masterplan’s 8.1 hectares and the qualifying provision shrinks to somewhere between 5 and 6.6 hectares, most generously counted — and only around 2.6 to 4.3 hectares of it is new. The real new parks are two: Chapel Park (1.26 ha) and Fruit Market Park (about 1.3–1.5 ha). Each is roughly the size of College Green. Between them and Sparke Evans Park, they are expected to host school play, neighbourhood events, ecology, gardens and the daily recreation of thousands.


The density arithmetic nobody has published

Bristol’s adopted standard for the city centre zone is 7.75 m² of recreational open space per person — itself barely a quarter of the 33 m² the average Bristolian enjoys citywide. Working through the strategy’s published figures shows that standard has been set with zero headroom: it assumes the central area’s population will rise 65%, offset by just 2.9 hectares of new green space, landing exactly on the 7.75 m² standard adopted.

The St Philip’s Marsh residents will get roughly 3.3 to 4.4 m² of qualifying green space per person on site, about one tenth of the citywide average. And that’s before you include the daytime population, who will share the same spaces: a workforce of 5,000 or more, several thousand students, and those whom the plan rightly invites in, living nearby in The Dings, Barton Hill, Totterdown and Redcliffe — some of the most green-space-deprived communities in Bristol. If the Masterplan’s population exceeds what the strategy assumed — and its unpublished assumptions are a question we’ve put to the Council — the adopted standard is breached simply by the arithmetic.


Five-minute-walk — from the front door, or the tenth floor?

We modelled walk times over the plan’s own street network. The average journey to the nearest named park is about three minutes. This supports the five-minute-walk promise. However, with roughly one in five residents living above the fifth floor in residential towers of ten storeys and more, this will add to the walk time just getting to the ground before setting off. For those households the five-minute promise quickly becomes longer. Sparke Evans Park, in the south-east of the site, is up to 21 minutes from the far north-west corner, while parts of the employment area are 7–10 minutes from any named park.

And five minutes for whom? The plan’s promise assumes a brisk walker covering 400 metres in five minutes. Bristol’s own parks standard describes that same 400 metres as a nine-minute walk — the pace of older people, small children, anyone with a buggy or those whose walking is impaired: exactly the people who parks matter most for. At that pace, every estimate above roughly doubles, and the far corner of the site is nearly 40 minutes from Sparke Evans Park. The five-minute-walk promise is really a 400-metre promise — which should be judged at the speed of the slowest, not the fastest.


Three thousand trees, ready by the 2050s?

The 25% canopy pledge needs 16–19 hectares of new tree canopy: in the order of 3,000 trees. These will largely be planted on streets that must also fit cycleways, drainage and utilities — creating a near-continuous tree ceiling over two-thirds of the public realm. Newly planted trees would deliver under 1% of site canopy on day one and take 25–40 years to mature, on top of the 20 years needed to complete the development. The 25% canopy pledge currently has no target date, no baseline and no monitoring. So for the first couple of decades, a resident on, say, the tenth floor will look down on saplings, not canopy — exactly what the international 3/30/300 benchmark (3 visible trees, 30% canopy, green space within 300 m) aims to prevent.


What we’re asking for

Our submission makes a series of specific requests, including:

  1. Correct the ambiguous reported park sizes.
  2. Reinstate the vanished quantification table.
  3. State the definitive site area and publish the boundary as open GIS data.
  4. Publish a schedule of open space that distinguishes real recreational space from public realm space, and test this against the projected full daytime population.
  5. Publish the population assumptions behind the quantity standard.
  6. Put a date, baseline, funding and monitoring regime on the canopy pledge.
  7. Front-load tree planting.
  8. Adopt 3/30/300 at design-code stage.
  9. Explain how and when the riverside open spaces will be delivered, given their dependency on the Avon Riversides 2100 flood defence programme — for which £88m has been identified against a further £128m still required.

None of this requires redrawing the plan. It just requires the Partnership to show its workings — because on green space, the difference between a promise and a number is where communities lose out, one planning application at a time.

One last thing. This document was meant to be a Supplementary Planning Document — statutory guidance sitting alongside the Local Plan. A change in Government regulations earlier this year means it will now be adopted only as an “endorsed Masterplan”: non-statutory guidance that developers must merely “have regard to”. That makes everything above more fragile, which is why our submission also asks for the green space framework to be secured through Local Plan policy wording, where it will have legal force.

The consultation closes on 28 July 2026. You can respond through the council’s survey or by emailing: hello@bristoltemplequarter.com — and if green space in this new piece of Bristol matters to you, please do.


Read our submission, with methods and maps, here:

SPM Masterplan Consultation – BTF Response

Analysis for this submission included independent measurement of the Masterplan’s Figure 07.34, georeferenced against Bristol City Council GIS data, and walk-time modelling over the illustrative street network, carried out with AI assistance (Claude, Anthropic) under our direction. Methods are set out in full in the submission’s annex.

The Local Nature Recovery Strategy and Bristol: a reassessment

In January 2025 we argued that the West of England Local Nature Recovery Strategy (LNRS) would do little to improve biodiversity net gain (BNG) in proposed development sites in Bristol. Since then, three things have changed enough to warrant a second look:

A follow-up to our January 2025 post, The Local Nature Recovery Strategy fails to deliver for Bristol.


  1. The emerging Bristol Local Plan has moved to the final stages of the public examination and the timetable for the 2045 Local Plan has been published.
  2. The West of England Mayoral Combined Authority (WECA) has published detailed guidance for developers and ecologists.
  3. We have been able to measure how much of the city the LNRS focus areas cover.

    These three changes mean that the picture is now more nuanced than a simple ‘fails to deliver’, but the practical conclusion is broadly the same. This post sets out why.

    What the latest LNRS has now made explicit

    WECA’s guide for planners, ecologists and developers, together with a dedicated BNG strategic-significance map, now spells out how the 15% Strategic Significance Multiplier uplift is meant to work. To attract the uplift, a proposed intervention must be in a mapped focus area for nature recovery and deliver a measure recommended (mapped) for that location.

    Two points in that guidance are worth dwelling on, because they confirm the argument we made in 2025 — this time in WECA’s own words.

    First, on baseline habitats. Our January post relied on Defra’s position that the multiplier applies only to habitats created or enhanced after development, not to what’s already on site – the baseline habitat. WECA’s FAQ now states this directly: the multiplier ‘is never applied to baseline habitats in the BNG Metric’. That is significant: it means the strategy can never reward the retention of existing habitat on a development site; but only new or enhanced habitats, and then only where a matching measure is mapped.

    Second, on where the mechanism is aimed. The single worked example in WECA’s guide is a developer purchasing off-site BNG units in a focus area. That’s a fair reflection of how the uplift is designed to behave: it’s a tool for steering off-site compensation and habitat banking towards priority locations, not something that typically assists the onsite footprint of a development itself.

    How much of Bristol is a focus area?

    In January we said it was ‘hard to imagine’ the LNRS helping on most Bristol sites, but we did not put a number on the coverage. We have now done so, using WECA’s own published data.

    Taking the Combined Authority’s mapped focus-area layer and clipping it to the official Bristol City Council boundary, 24.2% of the city — roughly 2,640 hectares of its 109 km² — lies within a focus area for nature recovery. (We checked the figure in two independent ways: a regular sampling grid and a random sample of over 90,000 points; both give 24.2%, and the method reproduces the city’s official area to within half a percent.)

    This is not a trivial share; anyone tempted to say the LNRS ‘barely touches’ Bristol should note that nearly a quarter of the city sits inside a focus area. But coverage is the wrong thing to count. That 24.2% is a ceiling — the maximum extent over which the multiplier could ever apply — before two much tighter filters are applied: the habitat being created or enhanced must match a measure mapped for that spot, and none of it can be baseline habitat.

    Coverage is not opportunity

    The more telling question is what is mapped, and where. When we count the individual measures that fall within the Bristol boundary, the focus areas turn out to be almost entirely watercourses and existing public green space that’s unlikely ever to be developed.

    LNRS measures mapped within the Bristol City boundary. Management/enhancement of existing habitat and watercourses (teal) dominates; new-habitat creation measures a developer could deliver on a site (amber) are comparatively few.

    River and floodplain measures dominate, followed by public parks & green space management and hedgerow, scrub and woodland under management. These are overwhelmingly measures for the management, restoration or enhancement of habitat that already exists — mostly along the Avon and Frome corridors, in the city’s parks, and on railway and river margins. This is land that is unlikely ever to be developed and, under the BNG regime, cannot be used to offset on-site habitat losses; BNG offsets may only be provided by registered Biodiversity Gain Sites (BGS). There are six in the LNRS but, currently, none are in Bristol.

    By contrast, the measures a developer might be able to deliver as new habitat on a site — creating woodland, hedgerows, wildflower meadow or mosaic habitat — appear only in the low tens of features and are themselves largely tied to the same green and blue corridors. So, the headline coverage figure and the practical opportunity point in opposite directions: a quarter of the city is mapped, yet the fraction of developable land where a scheme could both sit in a focus area and deliver a matching biodiversity improvement remains very small.

    The planning picture

    The wider planning position has moved on since January 2025, though not in a way that resolves the problem we identified at the time.

    Bristol’s emerging Local Plan completed its examination hearings last year with the final consultation has just completed. We are expecting the inspectors’ final report in the autumn so the plan is not yet adopted and still may not be. In the meantime, the Council having just published the timetable for the 2045 Local Plan which, when it starts this September, will not be completed until April 2029 at the earliest.

    Despite this, the two things we flagged in January still stand. No commitment has yet been made to designate any of Bristol’s focus-area sites — its parks, river corridors and green margins as BGSs available for off-site habitat mitigation — one route by which the uplift could be applied. Central Government has still not issued guidance on the role of the LNRS in planning decisions even though the Levelling-up and Regeneration Act requires plans to ‘take account’ of it. Until that guidance arrives, the strategy’s weight in day-to-day planning remains as defined under the BNG regime.

    Conclusion

    The LNRS is better documented than it was a year ago, and WECA deserves credit for setting out the mechanics clearly. On the specific question we raised in January 2025, that guidance has, if anything, confirmed our reading at the time: the multiplier cannot reward existing habitat. It is built for off-site delivery in priority locations rather than for the sites where most Bristol development happens. As none of these locations in the city are BGS sites, it is practically impossible to apply the 15% uplift they provide.

    The new coverage figure sharpens rather than softens the point. Yes, a quarter of the city is mapped as a focus area — but that land is the Avon, the Frome, in parks or railway land, all of which are already managed and enhanced in place. For a developer weighing up a site in Bristol, the chance that the strategy changes their BNG arithmetic is still low and, where it does, it will usually be through habitat bought outside the city.

    If the LNRS is to deliver the benefits promised for nature in Bristol, the gap is not in the mapping but in the mechanism: making suitable focus-area land available for off-site mitigation, and — as we suggested in January — allowing the city’s own adopted strategies, from its ecological network to its tree and green-space plans, to carry strategic significance where the LNRS does not.

    We suspect that this analysis is also likely to apply to other urban areas across England.


    Our earlier explanation of how strategic significance is assessed is set out in Assessing habitat parcels: strategic significance explained. Coverage and measure figures in this post were derived from the West of England Combined Authority’s LNRS layers on its Open Data Portal, clipped to the Bristol City Council boundary (ONS code E06000023), July 2026.

    Analytical research, policy review and initial drafting were undertaken with the assistance of Claude (Anthropic, 2025). All technical conclusions and professional judgements are those of the author.

    Understanding Biodiversity Gain Plans

    Since BNG became mandatory in February 2024, qualifying developments in England must show how they will deliver at least a 10% gain, to be set out in a Biodiversity Gain Plan (BGP) submitted to the local planning authority. We’ve transcribed 160 BGPs from 21 LPAs into a single, comparable dataset.

    What the data shows so far:

    • Just over under 60% (95 of 160) deliver their gain entirely on site. Another 34 use a mix of on-site and off-site measures, while 17 rely wholly on off-site units and 14 did not state an approach. Two bought Statutory Credits.
    • Off-site reliance is a recurring theme. A number of plans record an on-site biodiversity loss offset by purchased habitat units — a legitimate route, but one that moves the gain away from the community where the development happens.
    • Net gain has to be met habitat type by habitat type (area, hedgerow, watercourse), not as a single blended figure. Several plans that pass overall are marginal — or fall short — on an individual module.

    Accessing this data was harder than it should be:

    • There is no central register of gain plans – why can’t Defra or Natural England include them in their BGS allocation dataset? These documents should be easily accessible.
    • Each council’s portal has to be searched separately, with no consistent way of identifying the relevant application. Only a few authorities (City of York, Bristol and Cotswold among them) have a dedicated application category for BNG discharges. Otherwise the BGPs sit inside generic “discharge of conditions” applications and are very difficult to find.
    • BGPs are produced in a variety of forms – as clean PDFs, fillable forms, bespoke versions or scanned images requiring OCR – which is challenging, especially if they are hand-written.
    • They are often internally inconsistent: off-site figures just copied from the on-site section, credits confused with habitat-bank units, or headline numbers that do not reconcile.
    • Off-site claims frequently differ from what the Biodiversity Gain Sites register records as allocated.
    • Many applications do not include the required BNG Metric calculation.
    • Some applications can’t be analysed because all that is produced (and approved) is the certificate of the off-site HU purchase – and sometimes not even that. As a result, we’ve been unable to include these in our analysis.

    The information exists, but we can only conclude that the planning approval process makes meaningful public scrutiny far harder than it needs to be. Using the available standard Defra form and creating a single searchable register of BGPs would be a straightforward improvement.

    The full dataset and analysis are here — comments, corrections and more data are welcome:

    NB. This analysis will grow as we add more data.

    #BiodiversityNetGain #BNG #BGS #Planning #Nature #Transparency

    Losing our Local Green Space designations

    Are councils protecting our local green spaces? Our research reveals a worrying picture.

    Parks, playing fields, village greens and community orchards are vital for our wellbeing — places where children play, neighbours meet, and nature finds a foothold in our towns and cities. Yet our research suggests that many local councils are failing to use the powers available to them to protect these spaces, leaving them vulnerable to development and neglect.

    How we did our research

    Using Freedom of Information laws, we contacted 62 Local Planning Authorities (LPAs) across England, asking whether their current local plan includes policies protecting Local Green Space (LGS) sites, as set out in the National Planning Policy Framework (NPPF). We also asked them whether any new local plan would do so.

    The LGS designation was introduced in the NPPF in 2012 to give communities the power to protect the green areas that matter most to them. It remains part of national planning policy, and councils are expected to consider it when drawing up local plans.

    Of the 62 requests sent, 55 councils have responded (88%). Eight told us they don’t hold this information. That left 47 substantive responses from councils with real power over local green space protection. Eight councils have yet to respond. The full collated responses are available online.

    What we found: current local plans

    Of the 47 councils that gave a substantive answer, 17 — 36% — confirmed that their current local plan includes LGS policies in line with the NPPF. Twenty-three said their current plan does not, mainly because it predates the NPPF (2012). Bromsgrove, Redditch and Stoke-on-Trent all have plans dating back to 2009/2011 and so that lack LGS provisions, though Stoke’s does contain general green space protections.

    A further six councils gave qualified answers. South Hams, Stoke-on-Trent, Torbay and West Devon noted that designation of specific LGS sites has largely been left to Neighbourhood Plans. Solihull had adopted both an LGS policy and seven Neighbourhood Plans had also adopted their own LGS policies. This is a permitted approach, but one that places the burden on local communities rather than the council.

    What we found: future local plans

    The picture for future plans is only marginally better. Of the 47 substantive respondents, only 12 — 28% — gave an unqualified yes to designating LGS in their new or emerging local plan: Cheltenham, East Devon, Tewkesbury, Cannock Chase, Cotswold, Gloucester City, Bath and North East Somerset, Cornwall, North Somerset, Stratford-on-Avon, Swindon and Wyre Forest. Cotswold confirmed its 2025–43 plan will contain new LGS sites; Bath and North East Somerset (BaNES) proposes retaining and expanding its LGS policy, subject to Cabinet approval, and Stoke-on-Trent’s emerging plan contains LGS designations, a positive step for a city whose current plan predates the 2012 NPPF.

    A further nine councils said they do not intend to designate LGS at all. Birmingham will continue using strategic, criteria-based policies rather than site-specific designations. Tamworth explicitly ruled out using LGS designations, citing limited space and preferring broader open space policies. Rugby says its emerging plan ‘defers to national planning policy’, and South Gloucestershire, despite having LGS policies in its current plan, will drop them from its new one. Broader open space policies offer some protection, but not the strong protection that LGS provides.

    The largest group — 23 councils — said it was too early to tell or that no decision had been made, reflecting how slowly local plan preparation moves. Bournemouth, Christchurch and Poole, for instance, won’t be scoping consultation until June 2026.

    Solihull is currently working on a new Local Plan, and will be reviewing the status of Local Green Space sites and whether there will be any amendments or additions to these.

    The Bristol case: a warning from the front line

    Bristol offers a stark illustration of what’s at stake. While our FOI research was under way, Bristol City Council, at the request of the examining inspectors, was removing all Local Green Space designations from its emerging local plan. Its current plan had included policy GI1, designating LGS sites identified through years of community consultation involving residents, community groups and the Bristol Parks Forum (BPF), with a matrix showing how each site met the NPPF criteria.

    During examination, the inspectors rejected all proposed LGS designations as ‘not considered to be justified or effective,’ so the Council removed the policy entirely. BPF objects, pointing out that 14 sites met all five NPPF criteria and a further 27 met four, yet the Inspector rejected all designations en masse without considering the individual merits of each proposed site. BPF describe this as ‘a real disservice to the people of Bristol.’

    The Council argues Bristol’s green spaces will still be protected through ‘Reserved Open Spaces’ (now call ‘Protected Open Space’ (POS)) status, but both we and BPF reject this as inadequate. POS does not carry the same weight or permanence as LGS. Other cited designations, such as Site of Nature Conservation Interest (SNCI) status, will offer weakened protection in the new proposed local plan. BPF cites Brislington Meadows as an example of a site that lost out despite its status as an SNCI. BPF says:

    The only robust long-term protection for our locally important green spaces against development is to give a site Local Green Space designation. For a city like Bristol to have none is unbelievable.

    Notably, Bristol’s FOI response makes no mention of this removal, instead stating that under the new system introduced by the new Levelling Up and Regeneration Act 2023 (LURA), it has ‘not yet decided’ whether its new local plan will designate LGS sites.

    Both we and BPF are calling for the LGS policy and the proposed designations to be reinstated until a future local plan can provide equivalent or better protection, warning that any gap between local plans will leave green spaces exposed to development with no adequate defence.

    LURA: a planning system in transition

    Under LURA, there’s a transition deadline: plans submitted under the old system must be published by 31 December 2026. Authorities that fail to do this must use LURA’s streamlined 30-month timetable instead ­­— roughly half the current time required.

    This is, in principle, an opportunity: many councils currently without LGS policies are operating under plans that predate the NPPF, and the obligation to produce a new plan forces the issue. But the compressed timetable, reduced consultation, and a shift of generic policies to national level all create conditions in which LGS designation could be marginalised or skipped. The Bristol example, where the Inspectors rejected all proposed LGS designations en masse, demonstrates this.

    The role of Neighbourhood Plans

    Local Green Space designation has often been left to Neighbourhood Plans rather than local plans. Bristol, Plymouth, Torridge, Torbay, Rugby, Solihull and Newcastle-under-Lyme all have made Neighbourhood Plans designating LGS, even where their local plan does not. These designations carry real weight, but Neighbourhood Plans require significant community time and resource. Relying on them risks a two-tier system where well-resourced communities can protect their green spaces but those with fewer resources cannot.

    Why these issues matter

    Bristol is a symptom of a wider problem. Access to good-quality green space improves mental and physical health, supports biodiversity, helps manage flood risk, and strengthens community cohesion. In cities like Bristol — which declared an Ecological Emergency in 2019 and is involved in nature recovery initiatives — densification without adequate green space protection directly contradicts those commitments. When councils fail to use the tools available, a community may find itself powerless to save a local green space, sometimes valued for generations, once a development application arrives.

    What needs to change

    Councils preparing new local plans should treat LGS designation as a core part of the process, not an optional extra, and should engage residents early on which spaces matter most. The Planning Inspectorate should also assess LGS proposals on their individual merits rather than rejecting them wholesale, as happened in Bristol. Councils currently reviewing plans that predate the NPPF have a clear opportunity to put this right.


    What you can do

    • Get involved in your local plan consultation and make the case for LGS designation — and if your council is proposing to remove or weaken protections, say so clearly.
    • Ask your councillors whether your local plan protects local green spaces and what they’re doing about it.
    • Explore Neighbourhood Planning, which gives communities the power to designate LGS directly and may, in some cases, come with government funding.
    • Engage with council open-space strategies and green infrastructure reviews to help build the evidence base for future designations.
    • Support your local parks forum: organisations like the Bristol Parks Forum hold councils to account and amplify community voices. If your area doesn’t have one, consider helping to start one.

    The places where we walk, play, breathe and connect with each other and with nature are worth fighting for — but only if we use the planning system’s tools, hold councils to account, and make sure that our communities are genuinely heard.


    Speaking up for Bristol

    The last opportunity for us to comment on Bristol’s proposed local plan has now passed, so all we can now do is hope that the Inspectors change their minds and reverse their decision to revoke all proposed LGS designations.

    In any event, the Council assures us that it will publish its timetable for a further new local plan, as required under the new LURCA regime, by the end of June. When it does, we must insist that it reinstates its original ambition to adopt an LGS policy and designate LGS sites.


    A copy of this article is available here: Losing our Local Green Space designation – 16 June 2026

    Here are Bristol Parks Forum’s representations: Bristol Parks Forum response to Bristol Local Plan EXA064: Schedule of main modifications 11 June 2026

    Cotham School and the Stoke Lodge trees

    In its Information Statement of October 2025 concerning its recent fencing works at Stoke Lodge Playing Fields, Cotham School has chosen to misunderstand our concerns about the welfare of the trees at Stoke Lodge Playing Fields.

    The Information Statement includes the following:

    ‘In planning the work to reinstate the fence, the School wanted to respond to feedback, to improve safety by removing muddy paths, to respond to the Bristol Tree Forum concerns regarding footpaths impacting on the roots of trees protected by Tree Preservation Orders, to reduce any other ecological impact and to create an enhanced local open space.’

    Our complaints about the detrimental impact caused by the school’s original fencing layout on all the trees – not just the trees protected by Tree Preservation Orders (TPOs) – growing around the boundary of the site and on the playing fields were made in February 2020, nearly six years ago, in this blog: The trees at Stoke Lodge Park and Playing Fields – a letter to the Council. Cotham School has ignored these complaints and has never approached us to discuss our concerns.

    Furthermore, Cotham School’s decision to drive its new fencing through the root zones of several TPO trees, one of which is a veteran boundary oak, and to destroy other trees, some of which are protected by a TPO, makes it clear to us that the school continues to ignore the welfare of the trees growing at Stoke Lodge.

    We have reported these most recent breaches of TPO legislation to the Local Planning Authority. We have also made clear to Bristol City Council our concerns about the welfare of the Stoke Lodge trees generally. We have been ignored.

    As a result of this neglect, the long-term welfare of all the trees growing on and around the playing fields is at risk.

    Assessing habitat parcels: strategic significance explained

    To calculate the biodiversity value of a habitat, it’s important to assess its strategic significance. A habitat’s strategic significance takes into account both its type and its location. If strategic significance is high, then the habitat’s value will be uplifted by 15%. However, as this article explains, the opportunities for doing this are limited.

    A habitat parcel is an area of habitat which is all of the same distinctiveness, condition and strategic significance. Strategic significance refers to the importance of a habitat parcel based on its location and type.

    Each habitat parcel needs to be assessed both before, when the baseline habitat is surveyed, and after development, on or off site.

    This flowchart sets out how to assess the strategic significance of a habitat parcel. It uses the tables, shown below, from the Statutory Biodiversity Metric User Guide.


    Our blog, The Local Nature Recovery Strategy fails to deliver for Bristol assesses the implications of this for Bristol, which recently adopted the WECA LNRS.


    These are the tables referred to in the flowchart:

    Table 7: strategic significance categories where an LNRS has been published.

    Table 8: strategic significance categories where an LNRS has not yet been published.

    The Local Nature Recovery Strategy fails to deliver for Bristol

    WEMCA’s Local Nature Recovery Strategy (LNRS) will fail to provide Bristol with the benefits promised for nature. While the new Biodiversity Net Gain (BNG) rules require most development in the city to increase biodiversity by at least 10%, unfortunately the LNRS will not apply to most potential development sites.

    The West of England Mayoral Combined Authority (WECA as was) Local Nature Recovery Strategy was published to much fanfare last November. Defra’s blog, Kickstarting local nature recovery: a new strategy for the West of England, hailed it as the first in the country.

    The LNRS is a locally led and evidence-based strategy which aims to target action and nature investment where it’s most needed. We’re told that the strategy will also focus on biodiversity net gain by increasing the strategic significance of specific habitats. However, it is hard to imagine how the LNRS will help to enhance biodiversity net gain in most, if not all, potential development sites in the city.

    We might have been better off, at least as far as the application of biodiversity net gain to new development is concerned, by asking the LPA to specify alternative documents (such as those listed at the end of this article) for assigning strategic significance instead.


    The issue

    When calculating the impact of a proposed development on biodiversity, one factor taken into account is the strategic significance of any habitat found on a focus area for nature recovery site (coloured purple in the map above). If strategically significant habitats are created or enhanced, then their strategic significance is set to High in the Statutory Metric calculator tool and a 15% uplift to the calculation of its value is applied. Subject to which of the six LNRS areas is being considered, these are the strategically significant habitats in the city:

    • Ditches
    • Ecologically valuable lines of trees
    • Ecologically valuable lines of trees – associated with bank or ditch
    • Grassland – Floodplain wetland mosaic and CFGM
    • Grassland – Lowland calcareous grassland
    • Grassland – Lowland meadows
    • Heathland and shrub – Mixed scrub
    • Heathland and shrub – Willow scrub
    • Individual urban or rural trees
    • Lakes – Ponds (priority habitat)
    • Priority habitat (on the River Avon and the Riparian buffers)
    • Species-rich native hedgerow with trees – associated with bank or ditch
    • Species-rich native hedgerow with trees
    • Species-rich native hedgerows – associated with bank or ditch
    • Species-rich native hedgerows
    • Urban – Open mosaic habitats on previously developed land
    • Urban – Biodiverse green roofs
    • Woodland and forest – Lowland beech and yew woodland
    • Woodland and forest – Lowland mixed deciduous woodland
    • Woodland and forest – Other woodland; broadleaved
    • Woodland and forest – Wood-pasture and parkland

    However, a detailed examination of the LNRS map reveals that not all parks and green spaces have been designated as focus area for nature recovery sites. It’s only those which are in one or both of the following:

    • a location where they can make a greater contribution to ecological networks
    • deprived areas with a lack of access to nature.

    These designations were based on Bristol’s previous work on ecological networks within the city and where wildlife-friendly interventions are most likely to be feasible. This means that the existence, creation or enhancement of these special habitats outside these areas will not attract the 15% strategic significance uplift.


    The BNG requirements

    The now compulsory Statutory Metric Guide, used for calculating Biodiversity Net Gain (BNG), advises (at page 27) that: ‘Strategic significance is the local significance of the habitat based on its location and habitat type. You should assess each individual habitat parcel, both at baseline and at post-intervention, for on-site and off-site.

    If the LPA has adopted an LNRS then only the High or Low strategic significance multipliers can be used (High – formally identified in local strategy = 1.15. Low – area compensation not in local strategy = 1). If it has not adopted an LNRS, then the Medium strategic significance multiplier may also be used (Location ecologically desirable but not in local strategy = 1.10).

    Where an LPA has adopted an LNRS, all those sites which have not been identified as a focus area for nature recovery site will be designated as having Low strategic significance and so attract no uplift, even if they’ve been identified as important habitats in the Local Plan or in another strategic document adopted by the Council. These documents (used where an LPA has not adopted an LNRS) can include:

    • Draft Local Nature Recovery Strategies
    • Local Plans and Neighbourhood Plans
    • Local Planning Authority Local Ecological Networks
    • Parks and Green Spaces Strategies
    • Tree and Woodland Strategies
    • Area of Outstanding Natural Beauty Management Plans
    • Biodiversity Action Plans
    • Species conservation and protected sites strategies
    • Green Infrastructure Strategies
    • River Basin Management Plans
    • Catchment Plans and Catchment Planning Systems
    • Shoreline management plans
    • Estuary Strategies

    Baseline habitats cannot be uplifted

    Despite the BNG strategic significance guidance, Defra has stated that LNRS designations only apply to the creation or enhancement of post-development biodiversity mitigation habitats. They don’t apply if these habitats – called the baseline habitats – are found on the site before development begins.

    This means that the 15% strategic significance uplift can only be applied where offsite biodiversity mitigation is being delivered in a focus area for nature recovery site. If these habitats are being delivered elsewhere, the uplift may not be applied.

    However, even if the baseline habitats were included, it is unlikely to make any difference This is because the focus area for nature recovery sites identified in Bristol are, for the most part, located in public parks or green spaces, on river banks, in riparian buffers or on railway margins, none of which are likely ever to be developed or, in many cases, used to offset habitat lost to development elsewhere.

    So far, no announcement has been made as to whether any of Bristol’s focus area for nature recovery sites will be made available for offsite habitat mitigation and the proposed new Local Plan does not commit to using these sites for this purpose.

    This, combined with the challenge of finding LNRS suitable for offsite habitat mitigation, registering them as biodiversity gain sites and then managing them, effectively, in perpetuity, suggests that few feasible LNRS sites will be found, especially as many sites are also in demand for public access for recreation.

    We set out the process used to assess the strategic significance of habitats on our blog, Assessing habitat parcels: strategic significance explained.

    The 2025 Annual Tree Giveaway – free saplings available for planting

    Many thanks for of of you who have asked for trees – over 1,200!

    We have now closed the offer.

    Planting a tree is, perhaps, one of the most significant things we can do to help protect our future environment, promote nature and make the world a better place for the generations to come. The trees we plant today will continue to provide benefits for the environment, wildlife and people, for hundreds of years.

    A veteran chestnut

    We all know the value of trees in sequestering carbon, and they still represent the most effective and widespread means of removing CO2 from the atmosphere. For instance, a single mature oak tree is the equivalent of 18 tonnes of CO2 or 16 passenger return transatlantic flights. However, it is in our cities that trees provide the greatest benefits; cleaning our air, reducing flooding, improving our physical and mental health, and, crucially, reducing temperatures during heat waves.

    Our cities suffer additional problems during heat waves, with all of the concrete and tarmac absorbing a lot of energy from the cooling sun and releasing it as heat. This “heat island” effect can raise temperatures by as much as an additional 12 degree centigrade. Trees can greatly reduce, or even eliminate, this effect, partly through shade but also actively cooling the air by drawing up water from deep underground, which evaporates from the leaves… a process called evapotranspiration. According to the US Department of Agriculture, this cooling effect is the equivalent to 10 room sized air con units for each mature tree. This cooling greatly enhances our resilience to the dangerous heat waves that are predicted to increase in severity and frequency.

    A veteran Beech

    A stand of Silver birch

    Also, Trees improve air quality by absorbing both gaseous (e.g., NO2) and particulate pollution. They reduce traffic noise and flooding and improve physical and mental wellbeing.

    Thus, trees are a crucial, but often ignored, element in increasing our resilience to climate change.


    What are the Bristol Tree Forum doing to help?

    It is said that the best time to plant a tree is 20 years ago, and the second-best time is now.

    Unfortunately, important mature trees are constantly being lost to development, damage and disease. Though these might easily be replaced by new trees, what is less easy is replacing the decades or even centuries that the tree has taken to grow, the carbon that the tree has sequestered, the ecosystems the tree supports and all of the other benefits trees provide. For these reasons, most of the work of the Bristol Tree Forum focuses on protecting our existing trees. These efforts are particularly crucial in the urban environment where our trees are under the greatest threat.

    However, as well as advocating the retention of life-saving trees in our city, Bristol Tree Forum have been encouraging new tree planting by holding an annual tree giveaway since 2020; the ancient trees of the future are being planted today! Most of Bristol’s trees are sited in private land and gardens, so the trees we have are mostly thanks to the efforts of Bristol residents, and it is those residents we must look to if we want to increase our tree canopy.

    Over the last four years, we have given away around 10,600 trees, with species as diverse as English and Sessile oak, Downy birch, Silver birch, Grey birch, Alder, Alder buckthorn, Rowan, Scots pine, Sweet chestnut, Sycamore, Spindle, Wild cherry, apple, pear and plum.

    The trees planted to date.

    Trees given away in 2022 / 2023

    Red oak sapling

    This year’s Tree Giveaway has been made possible by the generous support of Maelor Forest Nurseries, based on the Welsh borders, and Protect Earth whose aim is to plant, and help people plant, as many trees as possible in the UK to help mitigate the climate crisis.

    Thanks to Maelor, we are able to offer a variety of species with a wide range of sizes and preferred habitats, including Pedunculate (English) oak, Red oak, Sweet chestnut, Silver birch, Sycamore, Hawthorn, Beech, Hornbeam, Wild cherry, Alder, Red alder, Field maple and Norway maple.


    Trees can be ordered using the form below

    We will get delivery of trees in February, when the trees can be collected from a site in Redland, Bristol. We will email you when they are ready.

    The saplings come bare-rooted (i.e. out of the soil) and will need to be planted as soon as possible after collection, although the viability of the trees over winter can be extended by storing the trees with the roots covered in damp soil.

    The form below is to find out who would like to have saplings for planting, which species, how many and where you plan to plant them.

    Please provide your email so we can contact you organise collection of the trees. Your contact details will be kept private and will not be used for any other purpose than to process your request.


    Our Giveaway offer has now been filled.

    Thanks for all your support.