Consultation on proposed changes to NPPF and the National Model Design Code

Individual planning decisions, development designs and local and national plans for development all impact local communities. We urge the Ministry of Housing Communities and Local Government to consider our views on the design codes and to continue to engage communities and groups such as ours in local planning decisions.

Here are our detailed responses to the consultation.


The changes proposed in Chapter 2 – Achieving sustainable development

Paragraph 7 – We agree with the introduction of the 17 Global Goals for Sustainable Development. These have been adopted by Bristol as part of its One City Plan so their adoption in the NPPF will be essential for ensuring that the city’s core planning policies are aligned with its wider goals.

Paragraph 8 states:

‘Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives).’

We would also like it to be made as clear as possible that these three overarching objectives are indeed ‘interdependent and need to be pursued in mutually supportive’ ways so that no one objective takes precedence over the others, as has been our experience with a number of recent planning decisions made in Bristol.

We propose that the paragraph amended to read: ‘Achieving sustainable development means that the planning system has three overarching objectives, which are interdependent and need to be pursued in mutually supportive ways so that no one objective is treated as having precedence over the others (so that opportunities can be taken to secure net gains across each of the different objectives)’

Paragraph 11 a) – We also endorse the proposed change that ‘all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects’. Trees are an important component of this, particularly where green space is limited.


The changes proposed in Chapter 3 – Plan making

Paragraph 22 – We agree that ‘where larger-scale development such as new settlements form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’. Too often, trees that were planted where a site was last developed (often only a few years before) are sacrificed to the short-term goals of the new proposal. Setting longer-term goals can help prevent this.


Proposed changes to Chapter 4 – Decision making

Paragraph 53 – Of the two options offered[1], we prefer the second – ‘where they relate to change of use to residential, be limited to situations where this is necessary in order to protect an interest of national significance’. In our view, the phrase ‘wholly unacceptable adverse impacts is open to too wide an interpretation which may not be rooted in wider national goals.

We agree that that Article 4 directions should be restricted to the smallest geographical area possible. 


The changes proposed in Chapter 8 – Promoting healthy and safe communities

We welcome many of the additions and changes proposed, including the recognition that a well-connected network of high-quality, open, green and wooded spaces is important for both our mental and physical health.

Paragraph 97 – We believe that access to a network of high-quality open spaces and opportunities for sport and physical activity ‘should always deliver wider benefits for nature and efforts to address climate change.


The changes proposed in Chapter 12 – Achieving well-designed places

Paragraph 128 – We agree that all guides and codes should be based on effective community engagement and reflect local aspirations for the development of their area.

Meaningful community engagement at all stages of the planning process is essential if the changes proposed are to succeed. Too often, communities are not asked to engage with planning proposals until they are published and the formal approval process has started. By this time most of the key decisions have been agreed between the developer and the planner and it is too late for any meaningful consultation with the wider community.

Paragraph 130 – We welcome the introduction of this new paragraph:

‘Trees make an important contribution to the character and quality of urban environments, and can also help mitigate and adapt to climate change. Planning policies and decisions should ensure that new streets are tree-lined, that opportunities are taken to incorporate trees elsewhere in developments (such as community orchards), that appropriate measures are in place to secure the long-term maintenance of newly-planted trees, and that existing trees are retained wherever possible. Applicants and local planning authorities should work with local highways officers and tree officers to ensure that the right trees are planted in the right places, and solutions are found that are compatible with highways standards and the needs of different users.’

We must learn to value our urban trees and woods growing in Bristol (and in other cities), so we were pleased to see this addition with the ambition to ensure that all new streets are treelined, but city-wide planning involving existing streets and road networks must also make space for new tree planting in the design process as well as ensuring that existing trees are retained.

Generally, planning requirements must be tightened to ensure that existing trees are retained. Only in exceptional cases where there are clear, justifiable and compelling reasons to do so should trees be removed. In all cases the cascading principles of the Mitigation Hierarchy must be applied and, where there is no option but to remove a tree, the loss of habitat and biodiversity that the tree provided must be compensated for by an adequate tree replacement calculation such as that used in the Biodiversity Metric calculation.

We agree that ‘development that is not well designed should be refused (paragraph 133). Designs that fail to make provision for preserving existing trees and providing new trees are not, in our view, well-designed and so should be refused.


The changes proposed in Chapter 13 – Protecting Green belt Land

New Paragraph 149 – We propose the deletion of this text, which is too general and open to interpretation. Certain other forms of development are also ‘not inappropriate in the Green Belt provided it preserves its openness and does not conflict with the purposes of including land within it’.

In Bristol there are just over 596 hectares of Green Belt left within the metropolitan boundary, mostly confined to the few remaining green margins of the city. The last draft of the Local Plan proposed the removal of some 50 hectares for development. Already parts of the Green Belt are disappearing without any hint that this ‘preserves its openness and does not conflict with the purposes of including land within it’. Little by little, development by development, Green Belt land is being lost.


The changes proposed in Chapter 14 – Meeting the challenge of climate change, flooding and coastal change

Paragraph 160 c) – Tree preservation and the planting of new trees are key elements of ‘using opportunities provided by new development and improvements in green and other infrastructure to reduce the causes and impacts of flooding, (making as much use as possible of natural flood management techniques as part of an integrated approach to flood risk management)’ We would like to see text added that states this.


The changes proposed in Chapter 15 – Conserving and enhancing the natural environment

Paragraph 179 d) – This states that ‘development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to improve biodiversity in and around other developments should be pursued as an integral part of their design, especially where this can secure measurable net gains for biodiversity and enhance public access to nature’.

It is essential that core planning policies mandate a standard metric for measuring baseline and created and enhanced habitat biodiversity proposals. Developers must be obliged to provide a Net Gain calculation when submitting their proposals. The latest version of the Biodiversity Metric Is designed for this purpose and should be mandated for all new planning proposals. All planning permissions should require the delivery of Biodiversity Net Gain plans of at least 10%.


We would be grateful for your views on the National Model Design Code, in terms of a) the content of the guidance b) the application and use of the guidance c) the approach to community engagement

The design codes must deliver three key things to ensure that new developments always provide access to high-quality, local green space and to trees, with all the benefits these provide for communities.


  • Protect and integrate existing trees  

New developments must incorporate and protect existing trees from the outset. There must be a presumption that the design will accommodate the existing trees growing on and around the site – especially those growing around the edges of sites. Designs should consider the long-term health of trees in and adjacent to new developments and aim to promote this. This will include providing adequate buffers for ancient, veteran and self-seeded trees and woods.

  • Increase canopy cover  

New developments must have a target of providing a combined minimum of 30% canopy cover on and off site. This should be made up of a mix of tree-lined streets, community woodlands, Tiny Forests, parks and gardens. Where tree provision will be made off site, the cost of providing, planting and caring for the trees on a long-term basis should be funded by the developer and incorporated into tree-specific S106 agreements (T&CPA 1990). Where possible, trees should be native and sourced and grown in the UK. Trees that will become large and are long-lived should be selected where possible.

  • Ensure trees thrive for the long term  
<p value="<amp-fit-text layout="fixed-height" min-font-size="6" max-font-size="72" height="80">Local authorities must be properly resourced so that they can implement design codes and other areas of planning policy. Resource needs to be available for decisions to be enforced and to ensure long-term management of trees by tree officers.Local authorities must be properly resourced so that they can implement design codes and other areas of planning policy. Resource needs to be available for decisions to be enforced and to ensure long-term management of trees by tree officers.
  • Community engagement

As we have already noted, meaningful community engagement is essential if communities are going to consider that they ‘own’ planning decisions rather than having them imposed on them.

We have published a paper on the issue as it relates to consultation on the management of trees which we commend to you: ‘Community engagement in urban tree management decisions: the Bristol case study’.

3 March 2021

You can download a copy of our submission here.

Here are copies of the draft National Planning Policy Framework and National Model Design Code.

The consultation closes on 27 March 2021 and can be accessed here – National Planning Policy Framework and National Model Design Code: Consultation proposals.


[1]  ‘a) where they relate to change of use to residential, be limited to situations where this is essential to avoid wholly unacceptable adverse impactsorb) where they relate to change of use to residential, be limited to situations where this is necessary in order to protect an interest of national significance’.

A letter to our Councillors

Dear Bristol City Councillors,

We recognise the fundamental importance of the natural environment, the value that nature has in an urban setting and the global threat posed by the ongoing climate catastrophe. We also recognise that trees are a crucial component in all these concerns.

We are supportive of Bristol City Council’s declaration of a Climate Emergency and an Ecological Emergency and the goals detailed in the One City Climate Strategy, including the commitment to carbon neutrality by 2030 and doubling the abundance of wildlife by 2050. We are also supportive of their commitment to doubling the tree canopy by 2046.

However, we have a real concern that the commendable words are not being matched by effective actions.

A principle aim of the BTF is to promote the planting and preservation of trees in Bristol for the well-being of its citizens, the sustainability of urban habitation, the enhancement of nature in the cityscape and as our contribution to combating climate change (see A Manifesto for protecting Bristol’s existing Urban Forest).

A recurrent concern we have is the continued loss of trees as a result of environmentally insensitive developments that are not sympathetic to the City’s declared commitments outlined above. On the other hand, the BTF supports developments that favour a sustainable environment over high density occupancy, and those that prioritise retention of existing trees.

Bristol’s policy on replacing trees lost to development – adhering to the Bristol Tree Replacement Standard (BTRS) – is widely well regarded. As such, decision makers believe that tree loss is mitigated by subsequent tree replacement. However, recent studies undertaken by the BTF have shown that this is not the case over the timescales committed to by Bristol City Council and the Green Party.

Typically, tree planting undertaken under the BTRS takes between 30 and 50 years to recover the biomass (and therefore the CO2e) lost by felling, well beyond the 10-year commitment on carbon neutrality, and even beyond dates set for doubling the tree canopy or doubling wildlife abundance.

The BTF study has been developed into a versatile online tool for calculating the extent and timescale of the carbon deficit, with a wide range of inputs. This can be accessed via the link Tree Carbon Calculator, and we encourage you to try this yourself. See also the BTF blog Tree replacement and carbon neutrality.

In the example shown here, a mature tree felled in 2020 is replaced by four trees (as per BTRS) of the same species. The carbon released (2 tonnes CO2e) is not recovered until 2064, a full 34 years beyond the date Bristol aims to be carbon neutral.

This model can also be used to determine how many replacement trees are needed to recover lost carbon within a particular timescale. In the example shown, to be carbon neutral by 2030, a reasonable expectation as this is the declared aim of BCC, the felled tree would need to be replaced by 37 plantings of the same species. Scaled up to, for instance, 500 trees, new plantings would need to number 18,500 to mitigate the lost carbon.

This new information represents a fundamental change in the evidence base for tree replacements, and emphasises the need to retain existing mature trees, and not to consider replacement by new plantings as adequate mitigation.

We request that you consider this new information with urgency and make a commitment to oppose developments where mature trees are removed and tree replacements do not deliver carbon neutrality by 2030.

A Manifesto for protecting Bristol’s existing Urban Forest

We invite all candidates standing in this May’s Mayoral and Councillor elections to endorse our tree manifesto which we set out here.

Bristol has declared a climate and ecological emergency. An emergency means making radical changes now – in every council department, by every developer, and by all those who own or care for trees.

All these proposals fit under Bristol’s existing 2011 Bristol Development Framework Core Strategy – BCS9 Green Infrastructure Policy which should now be implemented.  We must stop the needless destruction of so many trees in our city and instead learn to work around and with them.

Everyone from all sides of the political spectrum is talking about planting trees.  We fully endorse this, but it will take time for these new trees to mature. In the meantime, retaining existing trees will have the biggest immediate effect.

We propose that

  • There needs to be genuine community engagement in Bristol’s tree management decisions.  The council needs to listen to communities that want to save trees, not just to those who want to remove them.
  • Urban trees (planted or self-sown) have a tough life. Many bear the wounds and scars of previous damage or interventions.  These trees, though they may not be perfect, should be valued for the ecosystem services they provide and retained with appropriate and careful management wherever possible.
  • Alternatives to felling must be given priority, whether for street trees, or for those threatened by planning applications, or for other trees in the public or the private space.  
  • We need to strengthen planning policies to help retain trees on development sites by building around them, especially when the trees are on the edge of the site. 
  • Veteran and ancient trees require specialist management to ensure their retention whenever possible.
  • When surveys identify trees that present a risk, there should be consultation about the range of options available to mitigate the risk. This should always balance risk with the benefits the tree provides. Felling is only ever a last resort.
  • If trees must be felled, then more trees need to be planted to replace them. This should be based on well-established metrics used to calculate how to increase (not just replace) the natural capital of the lost tree.

Click here to print a copy of the manifesto. Candidates are welcome to download and use to support our aims.

Our Blogs contain many examples of the sorts of issues that have caused us to write this manifesto.