Bristol Tree Forum tree planting campaign – free Oak saplings available for planting

STOP PRESS

We delighted to report that nearly 1,600 tree orders have been received. We have bought another 600 trees to cover the extra orders and expect delivery soon.

Many thanks to all of you who have placed an order. We shall soon let you know when and where you can collect your trees.

Due to COVID-19 restrictions and delays in government funding, there has been postponements and cancellations of many major tree planting projects. As a result, large numbers of tree saplings are due for destruction in tree nurseries. This includes 750,000 two year old English oak tree saplings at the Maelor Forest Nursery in Wrexham.

Rather than see these trees destroyed, Bristol Tree Forum has purchased 1,000 of the oak saplings for free distribution to anyone able to plant them, whether this is one tree or a hundred.

We will get delivery early in November. The trees can be collected from a site in Redland, Bristol and a few collection dates will be organised hopefully to suit all. They should be planted as soon as possible afterwards.

The saplings are between 10cm and 90cm high. They come bare-rooted (i.e. out of the soil) and need to be planted as soon as possible after collection, although the viability of the trees over winter can be extended a little by storing the trees with the roots covered in damp soil.

This form is to find out who would like to have saplings for planting and how many, and for you to provide basic contact details (email and/or phone number) for us to organise collection of the trees. Contact details will not be used for any other purpose.

Why plant a tree?

A single mature oak tree is the equivalent of 18 tonnes of CO2 or 16 passenger return transatlantic flights.

Despite advances in carbon capture technology, the most efficient and cost-effective way to sequester carbon from the atmosphere is to plant trees.

Recent scientific reports calculate that planting trees wherever we can, without occupying land used for other purposes, would absorb up to two thirds of the carbon emitted in the last century.

Oak trees can support over 2300 different species, including birds, mammals, invertebrates, mosses, lichen and fungi.

Trees improve air quality by absorbing both gaseous (e.g. NO2) and particulate pollution.

Trees reduce traffic noise and flooding, reduce excessive heat in cities and improve physical and mental wellbeing.

Trees valued at over £4.6m are under threat at Bonnington Walk, Lockleaze

Whatever the merits of this application of achieving its primary goal to provide much needed housing may be, it should not be permitted to proceed unless and until it has properly addressed how it will replace and build upon the Green Infrastructure (including trees) that will inevitably be lost if this application proceeds as presently formulated.

Summary of our submission

We object to this application for the following reasons.

Bristol City Council has:

Declared climate and environmental emergencies.

Committed to becoming carbon neutral by 2030.

Committed to doubling tree canopy cover by 2046.

As currently formulated, these plans to build new houses can only set back the work needed to resolve these emergencies and achieve these commitments.

  1. The need to build housing to meet sustainable economic or social development objectives should not be allowed to take precedence over ensuring that the development is also both environmentally sustainable and meets Net Gain objectives.
  2. Whatever the merits of this application of achieving its primary goal to provide much needed housing may be, it should not be permitted to proceed unless and until it has properly addressed how it will replace and build upon the Green Infrastructure (including trees) that will inevitably be lost if this application proceeds as presently formulated.
  3. The existing trees have a significant asset value which should not lightly be ignored. Using CAVAT, we have valued them at £4,674,918.
  4. Under the Mitigation Hierarchy, trees should not be removed unless there is no realistic alternative. One alternative would be to build around the trees rather than remove them.
  5. BCS9 of the Core Strategy also states that “Individual green assets should be retained wherever possible and integrated into new development”. Clear felling nearly all the trees to the east of the cycle/footpath should not, as it so often is, be the default option.
  6. Trees should not be removed merely because they are diseased or self-sown, or because they are small or not perfect specimens of their species.
  7. The removal of existing trees inevitably means that the eco-services they provided will not be replaced for decades, if at all.
  8. The adverse knock-on environmental impact on biodiversity of removing existing trees far outweighs any short-term benefits achieved by replacing them.

Our submission

The planning background

The National Planning Policy Framework

The National Planning Policy Framework (NPPF) seeks to ensure that new development is sustainable. It stresses the importance of Green Infrastructure as one of three overarching, interdependent objectives – economic, social, and environmental. This means that the presumption in favour of sustainable environmental development is just as important as any in respect of economic or social development objectives.

Trees are an integral part of this because of the importance of trees in relation to the management of air, soil and water quality along with other associated ecosystem services, climate change adaptions and beneficial health effects. The NPPF also seeks to achieve the protection and enhancement of landscapes and achieve Net Gain in biodiversity.

The Natural England Joint Publication JP029 – Biodiversity Metric 2.0 (BDM2) provides a way of measuring and accounting for biodiversity losses and gains resulting from development or land management change. It defines Net Gain as an:

“approach to development that aims to leave the natural environment in a measurably better state than beforehand. This means protecting existing habitats and ensuring that lost or degraded environmental features are compensated for by restoring or creating environmental features that are of greater value to wildlife and people. It does not change the fact that losses should be avoided where possible, a key part of adhering to a core environmental planning principle called the mitigation hierarchy.”

The Mitigation Hierarchy

Avoid – Where possible habitat damage should be avoided.

Minimise – Where possible habitat damage and loss should be minimised.

Remediate – Where possible any damage or lost habitat should be restored.

Compensate – As a last resort, damaged or lost habitat should be compensated for.

This is a cascading decision process – only if the preceding choice is unavailable is the next considered.

Local Planning Authorities (LPA) in the UK have a statutory duty to consider both the protection and planting of trees when considering planning applications. The potential impact of development on all trees is therefore a material consideration. In particular, BCS9 of the Core Strategy states that “Individual green assets should be retained wherever possible and integrated into new development”.

We have summarised Bristol’s planning policies as they relate to trees here – Planning obligations in relation to trees in Bristol.

Summary of the proposal in relation to trees

This site covers just over six hectares. The Lockleaze Allotments (a 0.8 hectare Statutory Allotment[1]) is located to the south east of the widest part of the site. It appears to be disused. Most of the substantial trees growing on the site are growing in or around this allotment or to the north of it. We have calculated that, taken together, they cover at least 1.3 hectares of the site – a tree canopy cover (TCC) of around 20% which is well above the estimated TCC for Bristol as a whole which is just under 12%.

All our calculations, summarised below, can be examined in this linked spreadsheet.

The Arboricultural Impact Assessment Report (the AIS) dated June 2020 (based on a survey done on the 19th and 20th of September 2019) identified a combined total of 58 individual trees and 40 tree group features. The number of trees in each group is not given, so it is not possible to say how many trees in total are growing on the site.

Of all the trees growing on site 24 individual and at least 251 group trees are identified for removal. The trees growing in Groups G69 and G74 are all to be removed, but the number of trees in each group is not identified so we have not been able to include or count these in our calculations.

The only reason for given for felling these two groups is because they show evidence of Ash Dieback (Hymenoscyphus fraxineus). As the AIS recognises, the mere presence of Ash Dieback is not a sufficient reason for the removal of a tree. We oppose the removal of these tree unless it can be shown that they there is a better reason for their removal.

The CAVAT calculation

Using CAVAT we have calculated that those identified trees which have a measured stem Diameter (DBH) are worth £4,674,918.  As the AIS fails to give the upper life expectancy ranges[2] of the majority of trees, we have assumed that all those trees given a 10+ or 20+ years life expectancy will survive between 40 and 80 years. This attracts a 5% discount on the base valuation. We have applied a CTI factor for Bristol of 150[3]. All the other factors are set to their default values.

The BTRS calculation

These two tree groups and five individual trees are categorised as Category ‘U’ trees under BS5837:2012 Trees in relation to design demolition and construction, and so have not been taken into account for the purpose of the Bristol Tree Replacement Standard (BTRS) calculation. A further 10 trees are also excluded from the BTRS calculation because their stem diameters are under 15 cm. We advocate that all trees identified for removal should be replaced no matter what their size.

Notwithstanding this and based on the current guidance, we have calculated the BTRS value at 455 trees as per the AIS calculation.

Net Gain calculation

No Net Gain calculation has been undertaken using BDM2 in support of this application.

We have undertaken our own BDM2 calculation in respect of just the trees surveyed in support of this application. A full calculation needs to be undertaken in respect of the whole of the site. This will inform any future decision about achieving Net Gain if this development is to be allowed to proceed.

Using BDM2, we have calculated that the combined tree canopy cover[4] of just the known, measured trees is 1.21 hectares. We have set the A-1 Site Habitat Baseline Habitat Type to Urban – Street Tree in the calculation. This assumes, amongst other things, that any replacement trees will reach maturity in 27 years and so uses a multiplier of 0.3822 to reflect this.

This gives Base Habitat Units of 5.864 and a Base Replacement value of 3.17 hectares. If we add an arbitrary Net Gain value of 10%[5], then the Base Habitat Units increases to 6.451 and the Base Replacement value to 3.49 hectares. Assuming that a 27-year-old tree has a canopy of .00403 hectares, then 866 replacement trees are needed to replace what has been removed and to achieve Net Gain.

Loss of the ecosystem services of trees

We invite you to consider the decades-long damage that felling just one tree (let alone over 277 trees) will cause by inputting the DBH of any tree identified for removal into our Tree CO2 Calculator.

As you will see, when an equivalent tree is replaced on a one-for-one basis, the lost CO2e is never recovered. Even when the largest tree (with a DBH of 100 cm) is replaced with eight trees in accordance with BTRS, it will still take some 40 years to recover the 10.4 tonnes of lost CO2e. And this is just one of the eco-services that trees provide us!

Impact on wildlife from tree loss

We endorse the following passages from the Bonnington Walk Breeding Bird Survey Report which observes at 5.2 Habitat Loss:

The Proposed Development will include the loss of scrub, trees and buildings which provide habitat for breeding birds. The extent of habitat loss is likely to include all the scrub and trees in the centre of the Site with some edge habitat along the boundaries retained…The loss of this habitat will have an impact on any birds using it for foraging or breeding at the time. The Site is located within an urban landscape with limited natural habitats. Alternative habitats are not readily available adjacent to the Site, though alternative habitat is available in the wider landscape including Stoke Park Estate and connected habitats further east. Habitat loss on Site will have an impact at a Local level by reducing breeding bird habitat in the local area…

and at 6.2.1 Habitat Loss:

Where possible, habitat loss should be avoided, and natural habitats retained. Scrub and trees are of most value to breeding birds at this Site. When natural habitats are retained these should be protected during construction to prevent damage including root compaction and knocking off or damaging over hanging limbs.

This is just one example of the likely adverse impact on wildlife resulting from these tree removal plans. There is evidence of a diverse range of both flora and fauna that likewise will also be adversely affected by the loss of these trees.

The Bristol Tree ForumJuly 2020

You can find more detail about the application here:

20/02523/FB – Land on south side of Bonnington Walk, Bristol


[1] Owned by BCC under its asset number 8397.

[2] CAVAT uses six age ranges to set the discount factor.

[3] Bristol has a population of 459,300 and a land area (as opposed to the Administrative area which covers large parts of the River Avon and coastal margins) of 10,970 hectares. Using this gives a population per hectare of 41.9 (459,300/10,970) and so a CTI Index value of 150.

[4] Under BDM2 each tree’s Root Protection Area (RPA) is calculated at 12 times its stem diameter. RPA is roughly equivalent to a tree’s canopy.

[5] The choice is arbitrary chosen only for the sake of illustration. We are not advocating a Net Gain of 10%, though the concept of Net Gain implies an improvement on the base values.

Congratulations BCC on its successful Defra Urban Tree Challenge Fund bid!

Dear Bristol City Council,

We want to put on record our congratulations for the successful bid that your Parks Strategy team led for Bristol City Council to the DEFRA Urban Tree Challenge Fund (UTCF).  It has been some time in the resolution, but it is great that we now know for sure that it has succeeded.

We are delighted that there will now be more funds available to plant and maintain trees in the streets and green spaces of local communities that have perhaps been been overlooked in the past.

Thanks to you and to your excellent tree planting team, the Council has built an enviable reputation for planting urban trees across the city. Long may it continue!

We look forward to helping you with the planning and consultation that will be needed for adding these UTCF trees to next winter’s tree planting season.

This will make an important contribution to doubling Bristol’s tree canopy cover over the next 25 years.

We also applaud your decision to involve us in the collaborative partnership preparing the initial bid. As the only group specialising in protecting and caring for Bristol’s urban forest, we are very pleased to have been able to:

  1. Survey a representative sample of some of the 1,471 sites you have identified across the city, thereby relieving overstretched BCC officers who simply didn’t have the time to undertake this work.
  2. Adapt our Trees of Bristol website to record the planned planting locations for both street trees and the woodland sites.
  3. Develop our Tree Care site which communities will be able to use for post-planting tree maintenance and care – an important part of match funding the UTCF grant.
  4. We have also developed a comprehensive network of ward-based tree champions who are ready to be involved both in engaging with their local communities in the planned consultation and in helping with the ongoing care of newly planted trees.

As you can imagine, it was a lot of work, but we believe that it provided the sort of detail that helped clinch the bid.

Now that the funding has been secured, we look forward to meeting with you and the other partners to help with the next important planning phase of engaging with local communities and getting trees actually planted come next winter.

When can we meet to help you take this further?

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.

The trees at Stoke Lodge Park and Playing Fields – a letter to the Council

5th February 2020

Dear Bristol City Council Parks Department,

As you are aware, we have been expressing our continuing concerns about the welfare of the trees growing at Stoke Lodge Park and Playing Fields for the best part of a year now.

At the moment, our particular concerns are threefold:

  1. The potential for damage to trees caused by pedestrians being obliged to pass over their root zones and under their canopies since Cotham School erected its boundary fence last year.
  2. The potential for damage being caused to the trees growing within the new fence being caused by the school’s grass mowing regime.
  3. The potential for damage to trees caused by vehicles passing over their root zones and under their canopies.

To a large extend, our concerns about issue three may have been allayed by the school’s adoption of a new access point at the eastern end of the fields, but we will have to see how this develops.

The new vehicle access point at the eastern end.

As for the other two issues, we attach images showing how the very muddy and disturbed path running around the outside of the school’s fence is causing disruption to the root zones of a number of trees – these are not all the trees being affected by this.

The eastern end of the fields.
The path leading to the Pavilion on the northern boundary.
created by dji camera
The path leading to the Pavilion.

These images show how the current mowing regime encroaches within the root zone of one of the Turkey oaks inside the fence.

The Turkey growing at the eastern end of the playing fields seen from above.
The Turkey growing at the eastern end of the playing fields – the mowing line is clearly visible.

Here is a video which shows the mowing issue more clearly.

In our view, something needs to be done about this before any damage being caused becomes irreversible.

Can you advise me what action the Council plans to take to protect these trees, please?

Best Regards,

The Bristol Tree Forum

Council no longer manages trees on educational sites – Part II

Our worst fears have been realised. Schools have been left to care for the trees growing on their own sites, including those growing on school playing fields.

This blog follows on from our recent article on this subject – Council no longer manages trees on educational sites.

We have now had a response to a recent Freedom of Information request.

Trying to avoid the Council’s earlier refusals to answer our earlier FoIs about this, we asked for the same information as before, but just about one school which we selected randomly.

The school’s identity has no particular significance. We believe that these responses reflect the same situation across many other schools in Bristol (and the rest of the country?) – the lease disclosed is a Department for Education (DfE) standard Academy Lease’.

We asked…

[We] have been advised that Bristol City Council no longer maintains or manages trees growing on some sites owned by it.

In respect of Henleaze Junior School, is it a site where the responsibility for the care of the trees growing on its site has been passed to the school?

If so, please provide the following information:

1. Does the Council retain the ownership of the trees on the site?
2. If it no longer retains ownership, who does?
3. Does the Council still retain liability for any damage caused by trees on this site?
4. If it no longer retains liability, who does?
5. is this site available for tree planting by the public through sponsorship schemes such as TreeBristol or through tree-planting initiatives such as One Tree Per Child or the Urban Tree Challenge Fund?
8. Who makes decisions about the planting, maintenance or felling of trees on this site?
9. If it is not the Council, is the decision maker obliged to consult the Council before proceeding to maintain or fell a tree, whether or not the tree is growing in a Conservation area, or is protected by a Tree Preservation Order or is the subject of a planning application?

Please provide a copy of any lease entered into between to Council and Henleaze Junior School for the lease of its site.

The Council has responded to say…

The site is let to the Academy on a 125 year Department for Education standard Academy Lease.  The Council holds the Freehold of the site, but the responsibility for the management of the trees has passed to the Academy and the Council no longer retains liability for any damage caused by trees on this site?  The Academy does.

While the the site is available for tree planting by the public through sponsorship schemes such as TreeBristol or through tree-planting initiatives such as One Tree Per Child or the Urban Tree Challenge Fund, consent by the Academy is required for this.

The Academy is not obliged to consult the Council regarding the maintenance, removal or planting of trees on site and has the sole responsibility for these activities. This is subject only to any Tree Protection Orders (TPO’s) and/or Conservation Area requirements that may exist for trees on the site. In these cases, a planning application must first be made and permission given before the school can proceed.

A copy of the lease is available here. There is no mention of trees in the lease.

We are intrigued to note however, that the Council retains the right to develop the school and playing fields – Schedule Three – Rights Excepted and Reserved:

It appears very likely that similar arrangements to this will be found across most of the city’s 78 Academy schools (and possibly many Maintained and Special schools), by leaving them to make their own ad hoc arrangements to care for and/or plant trees as they may/or not desire.

Given that the One City Plan aims to double tree canopy cover over the next 25 years, it seems a great shame that this important land bank (we estimate some 188 hectares – land and buildings – for Academies alone) of possible new planting sites might have been excluded from helping to achieve Bristol’s ambitious plans.

What about protecting all the trees with a TPO?

There are already at least 3,400+ established trees growing on educational sites that could be at risk. As far as we can tell, very few of these trees are protected by a TPO, though some will be are growing in a Conservation area.

So, is it possible possible to protect all the remaining unprotected trees with TPOs? At least then all schools would be obliged to get planning permission before removing or ‘managing’ trees and we will be able to see what is planned.

Local Authorities have the power to make four types of TPO:

  • Individual TPOs: A single tree, illustrated as a trunk and approximate canopy spread. If trees merit protection in their own right, authorities should specify them as individual trees in the Order. 
  • Group TPOs: A group of trees, usually shown as a canopy, or group of canopies, with or without stems shown. The group category should be used to protect groups of trees where the individual category would not be appropriate and the group’s overall impact and quality merits protection. 
  • Woodland: Shown as an area of land. The woodland category’s purpose is to safeguard a woodland as a whole. So it follows that, while some trees may lack individual merit, all trees within a woodland that merits protection are protected and made subject to the same provisions and exemptions. 
  • Area TPO: Shown as an area, without stems highlighted. The area category is one way of protecting individual trees dispersed over an area. Authorities may either protect all trees within an area defined on the Order’s map or only those species which it is expedient to protect in the interests of amenity. 

We were recently been copied this answer when this issue was raised about some trees growing in the Bearpit:

Thank you for your email requesting a Tree Preservation Order for trees within the St James Barton roundabout/ Bearpit area. We have reviewed these trees following your TPO request. We understand that you are concerned about any future plans for the Bearpit which could affect these trees and the amenity they provide. 

The national guidance on ‘Tree Preservation Orders and Trees in conservation areas’ (https://www.gov.uk/guidance/tree-preservation-orders-and-trees-in-conservation-areas#making-tree-preservation-orders ) advises: 

“though some trees or woodlands may merit protection on amenity grounds it may not be expedient to make them the subject of an Order. For example, it is unlikely to be necessary to make an Order in respect of trees which are under good arboricultural or silvicultural management.” 

Furthermore, the potential effect of development on trees, whether statutorily protected (e.g. by a tree preservation order or by their inclusion within a conservation area) or not, is a material consideration. This means that tree matters must be taken into account by Bristol City Council as the Local Planning Authority when dealing with planning applications, and when undertaking consultations, and that members of the public can make clear their views. 

Given that these trees are already under existing arboricultural management, and that they would automatically be a material consideration should any future planning application come forward, it is not expedient or necessary for a Tree Preservation Order to be placed on these trees.

It appears that trees on educational land can, in theory, have TPO protection if it can be shown that they are not ‘under good arboricultural or silvicultural management’. But, how can the Local Authority know this?

However, our experience when we have requested that TPOs are made, is that the council will rarely do so, unless the trees are considered to have Amenity value and they are shown to be under immediate threat of destruction or damage. But, how can the Local Authority know this if the school is not obliged to tell them?

And…bitter experience has taught us that, whilst ‘…the potential effect of development on trees, whether statutorily protected…or not, may be ‘a material consideration’, other considerations often result in the welfare of trees being a very distant secondary consideration, with the result that they are frequently sacrificed to the too-oft-repeated argument that it is either the development or the trees, when there is no reason why it cannot be both.

So, the reality is that these trees are unlikely to be granted TPO status, save in exceptional circumstances and, even if they are, this is no guarantee of their future protection.

Our original concerns remain

We remain concerned that school governors (quite apart from lacking the necessary skills to manage the trees growing on their sites) may not yet have realised the full implications of the practical and strategic obligations that taking on such an important part of Bristol’s Natural Capital places upon them.

As a result, they are likely to buy in (at our eventual expense) ad hoc expertise, with the risk that they will overlook the wider strategic considerations that are needed when it comes to managing and promoting Bristol’s trees.

This, coupled with the distinct possibility that well-meaning, but unqualified Council officers in departments with no expertise in the management of trees may be making critical decisions about the welfare of trees across a wide range educational sites across the city, makes for a very worrying situation.

Our view is that the Council should take back the control and management of trees growing on land owned by it whether it is leased or not. Only then can we be assured that there is at least some degree of oversight and accountability, while helping us to achieve the wider strategic vision for the development of Bristol’s urban forest.

Changes agreed to Bristol Tree Replacement Standard

‘Only when the last tree has died, and the last river has been poisoned and the last fish has been caught, will we realise that we cannot eat money.’ – A Cree Indian speaking in the 19th Century.

Members of the Bristol Tree Forum (BTF) recently met with senior Planning Officers and the two Arboricultural Officers working in the Department. We wanted to raise a number of planning issues that have been concerning us.

The Bristol Tree Replacement Standard (known as BTRS – you can find it at page 21 of the Council’s Planning Obligations Supplementary Planning Document) is a flagship policy copied by other planning authorities. Bristol should be proud of it. We are because it goes a long way towards making sure that trees and tree canopy lost to development is replaced at the expense of the developers.

This is how the BTRS formula is applied (the diameters shown are in centimetres):

However, in the years since its inception about ten years ago it has become apparent to us that the policy could be improved if some changes to the way it is applied were made to it. Two things that have particularly concerned us are:

Firstly, it had become apparent that developers and householders developing land in Conservation Areas were avoiding their obligation to mitigate tree loss by submitting two separate planning applications – the first for the trees to be felled (usually for some spurious reason), then, months later, a substantive application to develop the now tree-free land.

Outside Conservation Area, where there is no protection for trees (unless they have a TPO) at all, the trees were simply being felled, sometimes in large numbers, some time before an application to develop the land was submitted.

In either situation, if the development was permitted, the trees were lost, never to be replaced, because the loss was not considered to be “in association with” the development of the land.

Secondly, if developers or householders were developing land and the BTRS was being applied, we noticed that in some cases, hedging was being approved as a replacement for the lost tree canopy. Whilst grand hedging might indeed be appropriate as part of the planning proposal – say as screening or as a pollution mitigation measure – we do not believe that it can ever be used as an adequate substitute for lost tree canopy.

In particular, we noticed that this option was being proposed by those developers who had filled nearly all of the site so that there was little, or no room left for replacement tree planting on site. In our view this was being done to avoid having to pay the Council (us really) for replacement trees to be planted nearby.

We are pleased to report that, after several meetings with Officers to discuss our concerns, the following has finally been agreed:

  1. Where there is evidence of prior felling, BTRS will be applied retrospectively to include all trees felled within the year before the planning application. In this way any trees felled before the development will be taken into account when considering the application of BTRS.
  2. Other than in exceptional circumstances, hedges will no longer be acceptable as mitigation for tree canopy loss when applying BTRS.
  3. If council officers think it is necessary, these new protocols will be written into the Council’s Planning Practice Note so that there is no possibility of any future misunderstandings by either developers or planning officers how BTRS is the be applied.

BTF has more ideas which we believe will strengthen the application of BTRS (for instance, why should trees under 15 cm not be replaced?; should BTRS be applied in non-development tree felling applications?) . We will continue to advocate for these and other possible changes.

We accept that there is always going to be development, but we must try to ensure that the city’s tree cover is, at the very least, protected and maintained in keeping with SDG 15 – Life on Land of the One City Plan Sustainable Development Goals which commit to doubling tree canopy cover by 2046.

Bristol’s i-Tree Eco survey is published

The study has revealed that there are some 600,000 trees growing in Bristol – and that they are worth £280 million to the city.

The study, the initiative of a partnership between us, Bristol City Council, the Woodland Trustand the Forest of Avon Trust, saw the latter work with 29 volunteers and local partners to help uncover the remarkable story of our Bristol trees.

Using the latest i-Tree Eco 6 model, the survey ran between May and September 2018 and has revealed that Bristol’s trees store around 360,000 tonnes of carbon dioxide and remove about 14,000 tonnes more each year – equivalent to the annual carbon dioxide emissions of some 9,000 cars.

The study also found that Bristol’s urban forest is worth around £280 million. This includes the cost of replacing the trees, plus the value of all the carbon stored in all the wood.

Each year trees in Bristol provide environmental services worth around £1.6 million, removing about 100 tonnes of air pollution and reducing flood risk by soaking up some 90,000 cubic metres of water thereby preventing this from running into drains and saving us about £140,000 annually.

Bristol’s tree canopy cover is currently around 12%. However, experts believe that this figure needs to increase substantially to help us combat the effects of climate change and air pollution, and protect biodiversity and promote our health and wellbeing. 

Bristol’s One City Plan, published in January 2019, is calling for tree canopy cover to be doubled by the end of 2045. That means adding another 1,316 hectares of new trees by adding around 53 hectares of new tree plantings annually for the next 25 years. This is an ambitious goal, but it could be achieved if everyone in Bristol planted just three new trees each.

Bristol’s Deputy Mayor, Councillor Asher Craig, said:

We have identified a need to increase the city’s tree canopy cover in order to enhance Bristol’s urban environment and provide a wealth of benefits. We are calling upon all citizens and businesses in Bristol to show their support for urban trees.

I am delighted that our partnership was recognised at the recent Street Trees Awards, as it shows we are moving things in the right direction.

Mark Ashdown, Chair of the Bristol Tree Forum said:

The Forum would like to commend Forest of Avon Trust for all their hard work and dedication to this important project. This report helps set the base line for the One City Plan’s goal to double Bristol’s tree canopy cover by 2046. It is an ambitious plan, but with the full support of Bristol City Council – ensuring that planners and developers always think ‘tree’, making sure that enough land is set aside for tree planting, protecting existing trees and ensuring that adequate funding is made available – we can all secure the future of Bristol’s urban forest and help Bristol’s citizens lead healthier, happier lives.

Jon Clark, Executive Director of the Forest of Avon Trust said:

I would like to thank the volunteers who helped us with this study, which makes the case that Bristol’s trees have a really important role in mitigating the growing impact of climate change in the city as well as in managing the health impacts of vehicle and wider CO2 emissions. Looking after the trees we have now and working with communities across Bristol to plant many more of them will make the city a healthier, more sustainable place to live and one in which people will be actively involved.

The Woodland Trust’s South West External Affairs Manager Catherine Brabner-Evans said:

Intuitively we know trees are good for us. They are the green lungs of our city. Urban trees bring life and colour, connecting us with nature, reducing stress, and boosting our mental health. Now we can also demonstrate the economic value of some of the services that trees provide. It is vital we protect our beautiful urban canopy and plant for future generations.

If you would like to help us plant, protect and care for Bristol’s trees, please complete our five-minute survey HERE. The survey closes on May 3rd, 2019.

To request a pdf of the full iTree Bristol report or to ask any questions about the study, please contact us or email Jon Clark at the Forest of Avon Trust.

Consultation – Protecting and Enhancing England’s Trees and Woodlands

Communities to have a greater say in protecting local trees…?

The Government has announced plans to create greater protections for trees in urban areas. The proposals would ensure councils can’t cut down street trees without first consulting their local communities.

The measures are intended to reflect the important role trees in towns and cities play in improving our health and wellbeing, as well as providing crucial environmental benefits.

The proposals include:

  • making sure communities have their say on whether street trees should be felled with requirements for councils to consult local residents.
  • responsibilities on councils to report on tree felling and replanting to make sure we can safeguard our environment for future generations.
  • giving the Forestry Commission more powers to tackle illegal tree felling and strengthen protection of wooded landscapes.

Interested parties have been invited to participate in the consultation. The proposals are based on the December 2018 paper, Protecting and Enhancing England’s trees and woodlands.

If you want to submit your own response, you will need to do so by 28th February 2018.

Here are Bristol Tree Forum’s responses to the questions asked:

Should a duty for local authorities to consult on the felling of street trees be introduced?

Yes.

It has been argued that it is too onerous for tree officers to consult on every single felling. Bristol Tree Forum believes that there are often alternatives to felling which should be considered, especially given how difficult it is to re-create canopy once it has been lost. Clearly, there should be consultation on a management plan to manage street trees. In other words if the goal is to stabilise canopy loss and even increase it, then a cost-benefit analysis has to be done to see if this might better be achieved by retaining an existing tree and managing its defects, or felling it and replacing with several new trees. The key is to consider street trees as capital assets. Thus, the cost of their replacement should be included in any management programme.

In addition, there should be consultation over planned major highways works to ensure that the minimum number of trees are lost, as well as taking the opportunity to maximise the possibility of planting new ones during the works.

Do you agree with the proposed scope of the duty to consult?

No.

Street trees form just one part of the urban forest.

Giving just street trees special protection without also protecting the wider urban forest and allowing consultation on all issues affecting the place of trees in the whole urban space, will result in the fragmentation of policies affecting the way the urban forest and its contribution to green infrastructure is managed.

Do you agree with the government’s preferred approach of a closed consultation with trigger point?

No.

These are the three consultation models proposed (the government’s preference is for option C):

Our preferred option is Option A: Full Consultation.

Placing notices just on trees will only inform those who happen to pass the tree and might or might not then take an interest.

At the very least, the notice should be published online.  This should not create an undue addition bureaucratic burden on Local authorities, as most will have tree management systems already in place that can be adapted to facilitate the automatic publication of these notices.

In this way those with a wider interest in the protection of street trees, such as Bristol Tree Forum and other community groups, will have an opportunity to engage in the process and offer comments and insights which those living locally (an area of just 100m2?) who are invited to make ad hoc comments in particular instances might not necessarily be aware of.

In any event, defining ‘local residents’ as just those living inside a 100m2 area is very unlikely to include all those who might take want to make a comment. For example removing a single tree from among many planted along a street is likely to be of interest to all the residents of the street, not just those living within 100 metres. Busy roads, where street trees are vitally needed, often have few residents. Another reason why it is necessary to involve local groups in consultation.

In what circumstances do you think a tree should be exempt from the duty to consult?

Only dangerous trees which present an immediate danger (‘immediate danger’ will need to be very carefully defined) where work is urgently needed to remove that danger should be felled without prior consultation. 

In all other circumstances, trees can be (and should have been) progressively managed in line with well-established risk management processes which will monitor any risk over time as it develops.

Even dead trees have a place in the urban biosphere, and may not necessarily need to be removed just because they are dead but do not present an immediate danger.

We are also concerned that, if the duty to consult is too widely exempted, it will undermine the wider purpose of this policy to require public bodies to consult.

In any event, all consultations should be “proper” as defined by Lord Woolf in R v North East Devon Health Authority, ex parte Coughlan [2001] QB 213 (para 108):  “…To be proper, consultation must be undertaken at a time when proposals are still at a formative stage; it must include sufficient reasons for particular proposals to allow those consulted to give intelligent consideration and an intelligent response; adequate time must be given for this purpose; and the product of consultation must be conscientiously taken into account when the ultimate decision is taken…”.

Do you think it is appropriate that trees of special historic or cultural significance are subject to a more rigorous consultation process?

Yes.

Do you agree with the criteria for designating a tree of special historic or cultural significance?

Yes.

Are there any other categories which should be included?

Trees falling within the definitions of Ancient and Veteran trees as set out in Natural England’s standing advice, “Ancient woodland, ancient trees and veteran trees: protecting them from development” should also be made subject to a more rigorous consultation process. For this to be effective, Local authorities will need to develop registers of ancient and veteran trees.

Also Trees subject to a Tree Preservation Order or growing in a Conservation Area where the Local Authority does not consider that a prior planning application is required because the proposed works fall come within Permitted Development Rights (or for any other reason) should also be included. See, for example, Bristol City Council’s response to Cotham School’s proposal to erect a fence around Stoke Lodge Playing Fields in such a way that trees protected by a TPO would be damaged; Bristol City Council did not require the school to make a planning application for prior consent to work in and around these trees because the works (it decided) fell within the school’s permitted development rights. The Council’s approach, which seems to be unique across the UK, has had the effect of denying the community an opportunity to make representations or offer comments as it would have been able to do had a planning application been required.

There also needs to be a process to allow TPOs to be put on important trees that are on public land, and to facilitate the process of consultation when this is being done.

Do you think that the duty to consult will have any negative impacts on development?

No.

Should consultations be done on an individual basis or in groups of trees where, for example, trees are planted in the same location?

The duty to consult will depend on the circumstances. In some cases it may be more appropriate to impose a duty to consult where a group of trees is likely to be affected – say a wood, copse or grove or were some or all of the trees in a given street are under consideration. In other circumstances, it will be sufficient to consult where only an individual tree is under consideration.

In addition, there should be proper consultation regarding the management principles to be taken into consideration when making a decision on any tree or group of trees.

Should a duty on local authorities to report on tree felling and planting be introduced?

Without open access to such decisions there is no way for communities to engage with decisions either on a case-by-case basis or in a wider and more long-term context where trends and outcomes may not be immediately visible but evolve over time.

Reports on planting should stipulate the size of trees, tree species and the category of spaces where they have been planted (e.g. streets).  Planting one street tree is several hundred times more expensive than planting a whip in a park, but it is not simply a numbers game.

Which trees would it be useful to report on?

All trees in the Local Authority’s tree stock need to be reported on and mapped. 

This might be on a tree-by-tree basis (such as street trees), or where clearly definable canopy areas can be mapped, and it is impracticable to survey every tree within the canopy. In many cases the importance of trees lies not just in their individual existence, but also in the contribution they make to overall tree canopy cover (TCC).

Please explain the reason for your answer.

Trees do not just serve an aesthetic role or provide visual amenity in the urban environment. Increasingly it is recognised that they also provide significant environmental and health benefits – carbon and pollution capture, rainfall run-off and heat island mitigation together with acknowledged health benefits are just some examples. It is now widely accepted that the effective management of urban tree stocks to enhance these effects has become an essential tool in helping public authorities and urban communities to mitigate some of the negative effects of living in the urban space.

So, if there is no understanding of what a Local Authority’s tree stock is, then there is little prospect of taking advantage of what it can and might offer.

What information do you think local authorities could gather and hold?

The data maintained by Bristol City Council and available as open data via its web page Open Data Bristol and its ArcGIS servers is a model of how Local authorities  can gather and hold information about their tree stocks.

How could local authorities present this information?

See our answer to question 16. There are many other similar examples across the UK.  By publishing its base data (preferably built on a consistent national data model structure) about tree stocks in an open access data format. Local authorities can also enable community engagement and so allow more sophisticated and enriched knowledge systems to be developed by local communities.

For example, Bristol Tree Forum has developed its sister Trees of Bristol web site which provides a much richer, interactive experience for users than is available just by presenting the raw data.

Should national Government play a role in collating and managing information?

Yes.

By publishing national best practice standards and devising a standard framework whereby data is gathered, including ensuring that the data generated is available through publicly accessible open data platforms and formatted to be machine readable.

Do you agree that Tree and Woodland Strategies help local authorities and the public to manage their trees and woodlands?

Yes.

Would best practice guidance be sufficient for local authorities and the public?

No.

Best practice is very important and must be encouraged, but without a legal framework which obliges Local authorities (and other public bodies) to comply with their obligation to consult and which gives communities a prompt and inexpensive way of obliging them to do so, there is little or any prospect of success.

Do you agree with the suggested content for best practice guidance for Tree and Woodland Strategies?

Yes

Government should produce best practice guidance to support local authorities in drawing up, consulting on and publishing their Tree and Woodland strategies to enable them to take a long-term, strategic approach to these resources, and provide another route for them to set out their tree policies clearly to the public and so increase transparency and accountability.

Do you support these measures?

Yes.

But there should be additional measures such as those addressed in this response.

Ancient and Veteran Trees explained

These two terms are in common use, but they have specific meanings when it comes to their conservation. All ancient trees are veterans, but a tree may qualify as a veteran without being ancient.  Most British trees increase in girth over their lifetimes by 2.5 cm a year. They grow faster when young, when in the open as opposed to woodland, and when in good soil rather than bad. They grow slower as they get older. Some species grow faster than average, such as Black Poplar, Plane, and Wellingtonia, and some more slowly, especially Limes and Hawthorns.

Trees are very good at vegetative reproduction, so that they are effectively eternal. Some create their own clumps, each tree being a clone. They do this by branches that arch down to the ground, root, and send up new vertical trees. The Tortworth Chestnut, which was regarded as ancient in King Johns reign, is a good example, but some of the limes on the Downs are doing this. Some trees send up new shoots from the base of the trunk which eventually replace the original tree. Many trees if cut to the ground, by storm or men, will promptly create new shoots, and this is the basis of coppicing which was a standard woodland management tool from at least Roman times. There is a Small-leaved Lime at Westonbirt Arboretum that now consists of a ring of clones about forty metres in diameter.

Ancient trees should be at least two hundred years old, and hence have a girth of more than five metres. I have measured 120 trees in Bristol with this girth, and there are many more in Ashton Court that I have not checked.   They matter because they provide a range of habitats to a range of species. They are always hollow, often squat,  having long since lost their upper branches, their hearts eaten out by fungi and beetles, full of nooks and crannies, and often clothed in lichens and ferns. They are most frequently Oaks, Sweet Chestnuts, Planes and Cedars.

Veteran trees are defined by their individuality. They will be mature, around 140/150 years old, about three metres in girth, mostly still standing tall. Fine, significant specimens of their species both in form and biodiversity. They are candidates to become Ancient, they may be starting to go hollow, and hence be of concern. They may need management to avoid their becoming top heavy, or developing a dangerous lean. They will stand out from other trees in their particular locality and may have planning protection as a consequence. They may also have special features of note, such as being multi-trunked.

Trees and Planning

The National Policy Planning Framework document (issued in July 2018) has the following definitions at Appendix 2: Glossary.

Ancient or veteran tree: A tree which, because of its age, size and condition, is of exceptional biodiversity, cultural or heritage value. All ancient trees are veteran trees. Not all veteran trees are old enough to be ancient, but are old relative to other trees of the same species. Very few trees of any species reach the ancient life-stage.

Ancient Woodland. An area of woodland that has been wooded continuously since at least 1600 AD. It includes ancient semi-natural woodland and plantations on ancient woodland sites.

Irreplaceable habitat: Habitats which would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their
age, uniqueness, species diversity or rarity. They include…ancient woodland and ancient and veteran trees….

Paragraph 175 (at page 51) of the framework states:

When determining planning applications, local planning authorities should apply the following principles:

c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists;

Paragraph 2.17.6 of DM17: Development Involving Existing Green Infrastructure – part of the Bristol Local Plan echoes this:

Due to their characteristics and value, Aged and Veteran trees are considered to be of relatively greater importance than other trees and even trees of a similar species. Aged trees, by definition, have developed characteristics associated with great age and often have particular landscape and townscape value. Veteran trees are considered to have particularly important nature conservation value. Both will often have significant visual amenity, and potentially historic and cultural importance. As such their loss or harm will not be permitted, and the design and layout of development will be expected to integrate them into development.

These guidelines apply whether the tree or woodland grows in a public or a private place.

R L Bland

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