Tree Strategy – Bristol Tree Forum

Our proposal for a new Bristol Tree Replacement Standard revisited

Following discussions with the Council about our recent proposal to revise BTRS, we have drafted a new version which we believe will strengthen tree protection across the city even further if it is adopted into the proposed new Local Plan.

Revisions are shown in red.

The latest version of the Biodiversity Metric (BNG 4.0), just published by Natural England,[1] is likely to become mandatory when the balance of the Environment Act 2021 comes into force later this year. We have revisited our June 2022 proposals and reviewed our calculations. We have met with Bristol City Council Officers and discussed possible alternatives with them. Here is the revised version.

The Bristol Tree Replacement Standard[2] (BTRS), adopted a decade ago, provides a mechanism for calculating the number of replacements for any trees that are removed for developments. It was ground-breaking in its time as it, typically, required more than 1:1 replacement of trees lost to development and within one mile of the development.

The presumption when considering any development involving established trees should always be that trees will be retained. The application of BTRS should only ever be a last resort. Providing funds in exchange for trees that are removed on development sites should not be the default choice which it seems to have become. In addition, in many instances, the locations of the promised replacement trees are not specified and the trees are never planted. As a result, section 106 tree replacement funds continue to accumulate to the 2023 figure of approximately £800K. This figure as barely changed over the years we have been monitoring it.

The starting point for any decision on whether to remove trees (or any other green asset for that matter) is the Mitigation Hierarchy. Paragraph 180 a) of the National Planning Policy Framework sets it out as follows:

If significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused.[3]

BTRS is and should always be ‘a last resort’. This is reflected in the Bristol Core Strategy, policy BCS9 adopts this approach and states that:

Individual green assets should be retained wherever possible and integrated into new developments.[4]

However, with the development of a new Local Plan for Bristol, we believe that the time has come for BTRS to be revised to reflect our changing understanding of the vital importance of urban trees to Bristol in the years since the final part (SADMP[5]) of the Local Plan was adopted in 2014.

In addition, Bristol has adopted Climate and Ecological Emergency Declarations so a new BTRS will be an important part of implementing these declarations. Nationally, the Environment Act 2021[6] (EA 2021) will come force later this year. This will require nearly all developments to achieve a Biodiversity Net Gain (BNG) of at least 10%. Our proposal provides a mechanism for complying with this new requirement and so aligns BTRS with the BNG provisions of the EA 2021.

Background

Under current policy – BCS9 and DM17[7] – trees lost to development must be replaced using this table:

Table 1 The Current DM17/BTRS replacement tree table.

However, when the balance of EA 2021 takes effect, the current version of BTRS will not, in most cases, be sufficient to achieve the 10% BNG minimum that will be required for nearly all developments. A new section 90A will be added to the Town and Country Planning Act 1990 and set out the level of BNG required (see Schedule 14 of EA 2021[8]).

The Local Government Association says of BNG that it:

…delivers measurable improvements for biodiversity by creating or enhancing habitats in association with development. Biodiversity net gain can be achieved on-site, off-site or through a combination of on-site and off-site measures.[9] GOV.UK says of the Biodiversity Metric that: where a development has an impact on biodiversity, it will ensure that the development is delivered in a way which helps to restore any biodiversity loss and seeks to deliver thriving natural spaces for local communities.[10]

This aligns perfectly with Bristol’s recent declarations of climate and ecological emergencies and with the aspirations of the Ecological Emergency Action Plan,^[11] which recognises that a BNG of at least 10% net gain will become mandatory for housing and development and acknowledges that:

These strategies [the Local Nature Recovery Strategies] will guide smooth and effective delivery of Biodiversity Net…

Our proposed new BTRS model

We propose that the Bristol Tree Replacement Standard be amended to reflect the requirements of the EA 2021 and BNG 4.0 and that the BTRS table (Table 1 above) be replaced with Table 2 below:

The Replacement Trees Required number is based on the habitat area of each of the three BNG 4.0 tree category sizes (Table 8-1 below) divided by the area habitat of one BNG 4.0 Small category tree (see section 3 below) plus a 10% net gain. This is rounded up to the nearest whole number – you can’t plant a fraction of a tree.

Replacing lost woodland

The current BTRS model does not deal effectively with the loss of woodland where it is impractical to measure individual tree sizes. Under BNG 4.0 these habitats are treated as Woodland and forest habitat and their habitat area is measured by the area they cover. We propose using the same method and adding 10% to allow for biodiversity net gain. The ratio will be 1 to 1.1 so that a woodland of, say, one hectare must be replaced with one which is 1.1 hectares.

The definition of a woodland is as set out in the UK Habitat Classification[12], w Woodland and forest: ‘Land with more than 25% cover of trees more than 5m in height.’

Replacing lost trees with hedgerows

The aim of BTRS is to replace lost tree habitat and canopy. Planting hedgerows cannot do this.

Whilst the planting of hedgerows is always to be encouraged, especially native species hedgerows, proposals to replace trees lost to development with hedging is very rarely a suitable solution and will not be permitted unless the developer is able to show that there are exceptional reasons for doing so. The planning arboricultural officer will need to agree the exceptional circumstances.

If a replacement hedgerow is permitted, this cannot be credited towards any BNG 4.0 calculation relating to trees. Hedgerows are a different habitat type, being linear as opposed to area based as trees are.

Making the BTRS calculation transparent

Often, years pass before trees lost to development are replaced and often the lost trees are only shown in the subsequent s106 agreement[13] as a single sum which was calculated years before and indexed to allow passage of time since the adoption of the Supplementary Planning Document (SPD) in January 2013.[14]

We would like to see a schedule set out in the S106 agreement and/or as a planning condition which itemises:

The number and identity (using Id used in the BS5837:2012 survey) of each tree to be removed.
The number and species of the trees to be planted on the development site.
The number and species of the trees to be planted on public land.
Which offsite trees are in to be planted open ground and which in hard standing.
The agreed location and species of each offsite replacement tree which and should be within one mile radius of the lost tree.
Trees planted under BTRS should not replace lost public trees, such as street trees removed in the normal course of tree management.
Like for like replacement. Compensation for the loss of large-form trees should result in large-form trees being planted.
Require that replacement trees or trees damaged as a result of the development that die within five years of planting will be replaced at the developer’s expense – This is the standard condition for trees planted on a development site.

The reasoning for our proposals is set out below:

Applying the Biodiversity Metric to Urban trees

The most recent Biodiversity Metric[15] (BNG 4.0) published by Natural England this April, defines trees in urban spaces as Individual trees called Urban tree habitats. The User Guide states that:

Individual trees may be classed as ‘urban’ or ‘rural’. Typically, urban trees will be bound by (or near) hardstanding and rural trees are likely to be found in open countryside. The assessor should consider the degree of ‘urbanisation’ of habitats around the tree and assign the best fit for the location.

Individual trees may also be found in groups or stands (with overlapping canopies) within and around the perimeter of urban land. This includes those along urban streets, highways, railways and canals, and also former field boundary trees incorporated into developments. For example, if groups of trees within the urban environment do not match the descriptions for woodland, they may be assessed as a block of individual urban trees.

Calculating Individual trees habitat

Table 8-1 in the BNG 4.0 user guide is used to calculate the ‘area equivalent’ of individual trees:

Note that the tree’s stem diameter will still need to be ascertained using BS:5837 2012,[16] and that any tree with a stem diameter (DBH) 7 mm or more and of whatever quality (even a dead tree, which offers its own habitat benefits) is included. Under the current DM17/BTRS requirement, trees with a DBH smaller than 150 mm are excluded, as are BS:5837 2012 category “U” trees. This will no longer be the case.

The Rule 3 of the BNG User guide makes it clear that like-for-like replacement is most often required, so that lost Individual trees (which have Medium distinctiveness) are to be replaced by Individual trees rather than by other habitat types of the same distinctiveness.[17]

Forecasting the post-development habitat area of new Individual trees

The BNG 4.0 User Guide provides this guidance:

8.3.13. Size classes for newly planted trees should be classified by a projected size relevant to the project timeframe.

most newly planted street trees should be categorised as ‘small’
evidence is required to justify the input of larger size classes

8.3.14. When estimating the size of planted trees consideration should be given to growth rate, which is determined by a wide range of factors, including tree vigour, geography, soil conditions, sunlight, precipitation levels and temperature.

8.3.15. Do not record natural size increases of pre-existing baseline trees within post-development calculations.

Our calculations are based on ‘small’ category replacement trees being planted.

Retain the community benefits of green assets

The current requirement that any off-site tree replacements are within a one-mile radius of the site should be retained. Were tree replacements to be allowed at any distance from the site, the local community that has lost trees due to a development would likely not benefit from their replacements. If trees lost in tree-deprived areas were to be replaced in areas with more available space and often more trees, the result would be greater inequality in tree cover. Currently, the most socially and economically deprived areas in the city centre have the lowest tree cover, and as these areas are also under the most pressure from developments, to lose this localism in tree replacement would lead to a further deprivation in tree cover for these communities.

The likely impact of this policy change

We have analysed tree data for 1,038 surveyed trees taken from a sample of BS:5837 2012 tree surveys submitted in support of previous planning applications. Most of the trees in this sample, 61%, fall within the BNG 4.0 Small range, 38% are within the Medium range, with the balance, 1%, being categorised as Large.

Table 4 below sets out the likely impact of the proposed changes to BTRS. It assumes that all these trees were removed (though that was not the case for all the planning applications we sampled):

The spreadsheet setting out the basis of our calculations can be downloaded here – RPA Table BNG 4.0 8-1 table Comparison.

Our proposed changes to DM17 and BTRS are set out in Appendices 1 and 2.

Appendix 1 – Our proposed changes to DM17: Development Involving Existing Green Infrastructure…

Trees

All new development will integrate important existing trees[18].

Development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) will be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists.[19]

Where tree loss or damage is unavoidable to allow for sustainable development, replacement trees of an appropriate species will be provided in accordance with the tree replacement requirements set out in the Council’s Planning Obligations – Supplementary Planning Document. …

Trees

2.17.6 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.

2.17.7 Trees are considered valuable multifunctional green infrastructure assets. This policy seeks to protect the most valuable trees and in line with the Core Strategy approach to green infrastructure assets, mitigate for the loss of other important trees by securing replacement trees on-site or in the public realm. The tree compensation standard set out in this policy provides a suitable mechanism to determine the appropriate level of mitigation where loss of trees is proposed as part of development.

2.17.8 The council’s Planning Obligations Supplementary Planning Document sets out the circumstances when off-site tree provision will be necessary. Where trees are to be provided off-site, planning obligations will be sought to provide the appropriate number of replacement trees, utilising the approach set out in the Supplementary Planning Document.

Appendix 2 – Our proposed changes to BTRS

Trees – Policy Background

The justification for requiring obligations in respect of new or compensatory tree planting is set out in the Environment Act 2021, Policies BCS9 and BCS11 of the Council’s Core Strategy and in DM 17 of the Council’s Site Allocations and Development Management Policies.[20]

Trigger for Obligation

Obligations in respect of trees will be required where there is an obligation under the Environment Act 2021 to compensate for the loss of biodiversity when Urban tree habitat is lost as a result of development.

Any offsite Urban tree habitat creation will take place in sites which are either on open ground or in areas of hard standing such as pavements and are located as close as possible to the site of the lost tree.

Where planting will take place directly into open ground, the contribution will be lower than where the planting is in an area of hard standing. This is because of the need to plant trees located in areas of hard standing in an engineered tree pit.

All tree planting on public land will be undertaken by the council to ensure a consistent approach and level of quality, and to reduce the likelihood of new tree stock failing to survive.

The trees planted will not replace lost public trees, such as street trees or trees in parks, removed in the normal course of tree management.

Level of Contribution

The contribution covers the cost of providing the tree pit (where appropriate), purchasing, planting, protecting, establishing and initially maintaining the new tree. The level of contribution per tree is as follows:

Tree in open ground (no tree pit required) £765.21
Tree in hard standing (tree pit required) £3,318.88[21]

The ‘open ground’ figure will apply where a development results in the loss of Council-owned trees planted in open ground. In these cases, the Council will undertake replacement tree planting in the nearest appropriate area of public open space.

In all other cases, the level of offsite compensation required will be based on the nature (in open ground or in hard standing) of the specific site which must be identified by the developer and is approved by the Council during the planning approval process. In the absence of any such agreement, the level of contribution will be for a tree in hard standing.

The calculation of the habitat required to compensate for loss of Urban trees is set out in Table 8-1 of the Biodiversity Metric (BNG), published by Natural England. This may be updated as newer versions of BNG become mandatory under the Environment Act 2021.

The following table will be used when calculating the level of contribution required by this obligation:

Were it is not reasonably practicable to ascertain the number or size of trees growing in a woodland, the level of compensation required will be 110% of the area covered by the trees, so that, for example, a woodland of one hectare will be replaced with one which is 1.1 hectares. The definition of a woodland is as set out in the UK Habitat Classification, w Woodland and forest: ‘Land with more than 25% cover of trees more than 5m in height.’[22]

The level of contribution required for planting trees in a woodland setting will be £[TBD] per 100 square metres.

Proposals to replace trees lost to development with hedging is very rarely a suitable solution and will not be permitted unless the developer is able to show that there are exceptional reasons for doing so and the planning arboricultural officer has agreed.

Planning obligations will contain the following:

The number and identity (using Id used in the BS5837:2012 survey) of each tree to be removed.
The number and species of the trees to be planted on the development site.
The number and species of the trees to be planted on public land.
Which offsite trees are in to be planted open ground and which in hard standing.
The agreed location and species of each offsite replacement tree which and should be within one mile radius of the lost tree.
Trees planted under BTRS should not replace lost public trees, such as street trees removed in the normal course of tree management.
Like for like replacement. Compensation for the loss of large-form trees should result in large-form trees being planted.
Require that replacement trees or trees damaged as a result of the development that die within five years of planting will be replaced at the developer’s expense.

[1]https://publications.naturalengland.org.uk/publication/6049804846366720

[2]https://www.bristol.gov.uk/files/documents/81-spd-final-doc-dec2012/file – Page 20.

[3]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

[4]https://www.bristol.gov.uk/files/documents/64-core-strategy-web-pdf-low-res-with-links/file at page 74.

[5]https://www.bristol.gov.uk/files/documents/2235-site-allocations-bd5605/file

[6]https://www.legislation.gov.uk/ukpga/2021/30/contents/enacted

[7]https://www.bristol.gov.uk/files/documents/5718-cd5-2-brislington-meadows-site-allocations-and-development-management-policies/file page 36.

[8]https://www.legislation.gov.uk/ukpga/2021/30/schedule/14/enacted

[9]https://www.local.gov.uk/pas/topics/environment/biodiversity-net-gain.

[10]https://www.gov.uk/government/news/biodiversity-30-metric-launched-in-new-sustainable-development-toolkit.

[11]https://www.bristol.gov.uk/documents/20182/5572361/Ecological_Emergency_Action_Plan.pdf/2e98b357-5e7c-d926-3a52-bf602e01d44c?t=1630497102530.

[12] https://ukhab.org/

[13]https://www.legislation.gov.uk/ukpga/1990/8/section/106

[14]https://www.bristol.gov.uk/files/documents/81-spd-final-doc-dec2012/file

[15] https://nepubprod.appspot.com/publication/6049804846366720

[16]https://knowledge.bsigroup.com/products/trees-in-relation-to-design-demolition-and-construction-recommendations/standard

[17] Table 3-2 Trading rules (Rule 3) to compensate for losses. Any habitat from a higher distinctiveness band (from any broad habitat type) may also be used. [18] Need to define what ‘important means.

[19] This is based on NPPF para. 180 c). We have inserted ‘will’ instead of ‘should’.

[20] These references may need to be changed to reflect any replacement policies adopted with the new Local Plan.

[21] These values should be updated to the current rates applicable at the time of adoption. The current indexed rates as of June 2023 are £1,171.79 & £5,082.29 respectively.

[22]https://ukhab.org/

The vital role of trees in urban development

There’s a climate emergency and we need to act. With higher temperatures and more severe weather events than just a decade ago, we must take action at the local as well as the global level.

Bristol City Council declared a Climate Emergency in 2018, reflecting the need to reduce the city’s contribution to the causes of climate change, and to adapt and be resilient to further expected climate impacts. For the declaration to be meaningful, it has to result in practical changes, for example the protection of existing trees on development sites. With important urban trees being routinely felled, there is no evidence that this is the case. If Bristol continues in this way, the city will become unliveable in the climate crisis.

The Council is now drafting a tree strategy for the city, which we hope will become a key element of the forthcoming revised Local Plan. We hope that the strategy will protect existing trees and prioritise the planting of replacement and new trees across the city. We have asked for 18 principles to be included in the strategy.

If our urban environment is going to be liveable in the long term, we need to create new developments that can cope with the changes in the local climate expected in the future. The benefits of trees in the fight against climate change are now well understood: trees lock up carbon, reducing pollution and flooding. They are also the best way of reducing the urban heat island effect, decreasing the temperatures of heatwaves by up to 10°C . It’s therefore vital that green infrastructure forms part of any proposed development. This is particularly crucial in the city centre.

On every occasion that trees are felled, we’re told it will be all right, as they will be replaced. Often these replacement trees are never planted because there is nowhere to plant them, or if planted, they die and are not replaced. At any rate, we need tree canopy and shade now, not in 50 years’ time when any new trees that might survive will replace the canopy lost. This is why we must protect existing trees, and if trees must be lost, local tree replacements must be planted and not just promised.

A warmer climate increases the risk of overheating and heat-related illness, even death. In the heat wave of 2003, around 70,000 people died across Europe due to the extreme heat, with older people and children particularly vulnerable. However, we can reduce much of the risk without the need for active cooling, by incorporating effective measures into development proposals from the earliest design stage. New buildings and external spaces must be designed to provide year-round comfort and support well-being. On-site tree planting for shade will contribute to this by minimising the amount of heat entering buildings. All new developments will be expected to demonstrate through ‘sustainability statements’ how they would incorporate such measures into their design from the outset.

How green (and blue) infrastructure reduces climate impacts

Developers must take into account that changes in the local climate are likely to: increase flood risk and water stress; change the shrink-swell characteristics of clay soils affecting foundations and pipework; affect slope stability; and affect the durability of building materials. Incorporating green and blue infrastructure, such as trees and water features, in developments will help to reduce all these effects. Green and blue infrastructure should be multifunctional, that is, provide ecology and biodiversity benefits as well as climate adaptation in developments. Where appropriate, this should include the use of living roofs with a sufficient substrate depth to maximise cooling benefits. However, the cooling effect of green roofs is a fraction of that afforded by trees.

Long-term thinking

As we build more homes, businesses and communities, it’s essential that we retain and integrate important existing trees within any new development. We must also consider carefully the size, species and placement of new trees provided as part of any planned landscape treatment, for example in terms of:

ensuring that any new streets are tree-lined
focusing once again on large-form trees that will be long-lived and provide substantial shade, rather than small, short-lived trees such as Rowan or Amelanchier
reducing or mitigating run-off and flood risk on the site
increasing on-site canopy cover and providing shade and shelter
ensuring that newly planted trees will be maintained in the long term and replaced if necessary.

Where tree loss or damage is unavoidable, and not merely expedient, within a development site, new replacement trees of an appropriate species must be provided either on or off site and their long-term management and maintenance secured.

We have submitted our proposals for how trees lost to development should be replaced as for of the Local Plan Review – Our proposal for a new Bristol Tree Replacement Standard using Biodiversity Metric 4.0

Developing a Tree Strategy for Bristol

Bristol City Council is currently writing a tree strategy for Bristol. This is welcome news, as we have been calling for such a strategy to be developed for more than a decade.

For example, in 2020 we wrote a Manifesto for Protecting Bristol’s Urban Forest.

A tree strategy should be an evolving process rather than a document which may quickly become out of date. This is particularly true in our rapidly changing world – environmentally, climatically and politically. To provide an effective response to the challenges these present, a group of representatives from both civic and professional groups (along the lines of the Bristol Advisory Committee on Climate Change (BACCC), should be established to help coordinate further research and make recommendations to Bristol City Council and other stakeholders as the situation changes.

We also recommend that the development of a tree strategy should take full advantage of exemplars from other local authorities[1]. We should have the ambition to make Bristol’s tree strategy the best.

Here follow 18 key points that we would expect to see included in a strategy.

Buy in from all the stakeholders involved. Many council departments (as well as Parks, there is Highways, Education and Planning) have a role to play in the management of Bristol’s trees. We need to see evidence that all such departments are fully involved in the development of the strategy. In particular, with the current review of the Local Plan, it is essential that Planning is fully engaged with the strategy, and that the two documents are consistent and properly cross-referenced. The tree strategy needs to be incorporated into the new Local Plan. In addition, other important landowners (such as the universities, utilities providers, housing associations, schools and hospitals) have a role to play in contributing their expertise to the strategy and implementing its goals. As well as the Bristol Tree Forum, many community groups have an interest in tree planting in Bristol and should be involved and consulted.
When council trees are removed, they must be replaced. At present there are more than 800 street tree stumps and empty tree pits around the city – sites where trees once grew. A plan to plant all these missing trees within five years needs to be included. In the future, when any council trees are damaged or felled, they should be replaced within the next planting season.
There needs to be community engagement in tree management decisions both at the level of individual trees and in strategic decisions. In recent years we have seen a rise in community led campaigns to protect trees, such as the Ashley Down Oak, the M32 maples and Baltic Wharf, and this is indicative of a disconnect between the Council and the communities it serves. When the balance of the Environment Act 2021 takes effect later this year, Councils will be obliged to consult when street trees are being considered for removal[2]. This is too narrow and should be extended to include where any public tree is being considered for removal. Therefore, part of the strategy should be promoting community engagement, providing mechanisms for engagement and then taking account of the concerns of the community and tree campaigners alike.
There should be one person responsible for trees within Bristol City Council. At present we have tree planning officers, tree maintenance officers and tree planting officers with no single individual or office accountable overall, often resulting in a lack of appropriate action or people working at cross-purpose. It is also concerning that Highways are able to remove street trees without any consultation.
There needs to be a plan to address the massive inequality in tree cover in Bristol, which often mirrors social and financial deprivation in the City. For instance, additional protections could be given to trees, and tree planting prioritised, especially in deprived areas such as the City Centre, Harbourside and St Pauls.
When developers remove trees, the replacements required should be planted by BCC. Too often developers have shown themselves incompetent or unconcerned when planting trees, so the trees fail or are never planted. In the case of Metrobus, there has been a more than 100% failure rate of trees in some places (trees have been replaced multiple times). We have an excellent tree planting team in Bristol and we should benefit from requiring them to organise and implement the planting required. The cost should be funded by the developer.
Retaining existing trees must be a major part of the strategy. A tree strategy cannot be just about planting new trees, the benefits of which will not be realised for decades, but crucially about retaining and protecting existing trees and the benefits they are already providing. As such, the strategy must address the threats to existing trees. Planning is crucial in this so we would expect major engagement with Development officers to address the current and future problems.
Planning Enforcement must address the illegal removal of or damage to trees. At the moment there are no consequences following the unauthorised damage or destruction of trees. This must change. Other neighbouring local authorities manage to do this but not Bristol. A strategy must include a review of the reasons for the existing lack of effective enforcement and make recommendations as to how this can be rectified.
Developments should be built around existing trees as is already required[3]. Other local authorities do this but not Bristol. This will require a change of culture in the planning department so that pre-application discussions with developers make it clear that this will be required.
The sites for the replacement trees must be agreed before Planning Applications are approved. This is required by planning policy (BCS9 and DM17), but currently developers are being allowed to, instead, pay a “fee” into Section 106, and frequently the replacement trees are never planted. Trees form an important part of our urban habitat. The calculation of tree replacements required to compensate for their loss must be aligned with the Biodiversity Metric as adopted under the Environment Act 2021.
Spend the £ 900K+ reserved for tree planting. Connected with the above point, a strategy needs to include a mechanism for spending the existing £900K+ of unspent tree planting Section 106 money within the next three years.
A strategy to increase Bristol’s tree canopy cover (or at the minimum, maintain existing canopy cover) needs to have a route to implementation. This must include addressing the loss of street tree canopy cover by being bolder in selecting new tree planting sites and planting large-form trees wherever possible. Trees such as rowans and flowering cherries are short-lived and will never provide much canopy or become robust enough to survive our challenging urban environment in the long-term.
Canopy Cover needs to be measured with an agreed methodology with confidence limits (levels of doubt in the estimate) made clear. In the first instance, we need to establish the baseline year and percentage tree cover from which progress will be measured. Only then will it be possible to show whether a trend has been determined. Two measurements using different methodologies should not be used to claim an increase in canopy cover. The metric should take account of trees lost so that the figure reflects the true increase, or loss.
Include trees within road changes. There needs to be proper engagement with Highways at early stages of the design process for road changes to look at retaining the maximum number of existing trees and including innovative planting opportunities for new large-form trees, such as pavement build-outs.
For new developments, trees should be properly considered at the pre-application stage, with appropriate consultation with stakeholder groups. Too often, the mitigation hierarchy requiring the removal of trees to be a last resort is disregarded, so that it is only after the design has been finalised that the existing trees are considered and removed where they conflict with the design scheme.
Biodiversity Net Gain (BNG) calculations need to be checked by the Local Planning Authority and biodiversity loss must not be monetised as BTRS has been. BNG, if properly implemented, makes sure that biodiversity on development sites is properly measured and will provide a net gain (soon to be least 10%) is factored in. However, at present, developers’ calculations are not being checked. When we have provided properly evidenced calculations, these have been dismissed by the LPA as mere differences of opinion. You cannot have differences of opinion on facts. The LPA must require that BNG calculations are presented in a way that can be checked by anyone interested and actually do the checking. In addition, ensuring BNG must require that the development site does not lose its biodiversity. If this is not possible, then its immediate local environment must be used to offset any onsite losses. Onsite losses must not be compensated for in some faraway place completely removed from Bristol.
Planning Applications involving trees must mention this fact in the title. Too often, applications that involve the loss of important trees (or plans to avoid the planting of new trees[4]) do not even mention this fact in the title. This means that it is extremely difficult for community organisations to engage.
Once a planning application has been issued, no removal of trees. A moratorium should be placed on any tree felling pending the outcome of the planning application. This includes applications to demolish buildings which should exclude tree or other habitat removal.

A copy of this blog is available here.

02 May 2023

[1] See for example the Wycombe Council Canopy Cover Doc https://buckinghamshire-gov-uk.s3.amazonaws.com/documents/Canopy-Cover-SPD_3qAkk4z.pdf

[2] https://www.legislation.gov.uk/ukpga/2021/30/part/6/crossheading/tree-felling-and-planting/enacted

[3] Bristol Core Strategy, policy BCS9 states that, “Individual green assets should be retained wherever possible and integrated into new Developments.”

[4] See the Avon Crescent Application pp136 – 155 https://democracy.bristol.gov.uk/documents/g10675/Public%20reports%20pack%2010th-May-2023%2014.00%20Development%20Control%20B%20Committee.pdf?T=10

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.

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.
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.
The existing trees have a significant asset value which should not lightly be ignored. Using CAVAT, we have valued them at £4,674,918.
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.
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.
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.
The removal of existing trees inevitably means that the eco-services they provided will not be replaced for decades, if at all.
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 Forum – July 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.

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:

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.
The potential for damage being caused to the trees growing within the new fence being caused by the school’s grass mowing regime.
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 path leading to the Pavilion on the northern boundary.*

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 I

There are some 166 educational sites and 63 playing fields across the city. Together they cover over 560 hectares and form a significant proportion and an important part of the city’s open, green spaces.

This is the Part I of a two-part blog – here is Part II.

Despite this, Bristol City Council no longer manages trees growing on many of these sites and their related playing fields. We are not certain, but we imagine that this situation has come about as a result of the decline in local authority control over state educational provision with the rise of independent Academies.

We issued a Freedom of Information request (FoI) to try to find out which sites remain under the control of the Council, but our request has been refused on the grounds that answering it would impose a significant burden on the council. Our more generic request at the end has also been refused on the same grounds.

The trees at Stoke Lodge Playing Fields

Recent events at Stoke Lodge and the playing fields there perhaps best illustrate our concerns and the potential threats to the many trees growing on land set aside for educational purposes.

The site was leased for 125 years to Cotham School in August 2011. Interestingly, the Council agreed to retain its responsibility for all the trees growing on the site. It also agreed to indemnify the school for any damage the school might cause to the trees and to insure against this risk.

Stoke Lodge Playing Fields are located to the west of the city in Stoke Bishop ward and cover some 8.7 hectares of open space. Historically they were part of the grade II listed lodge (now an adult learning centre) of the same name which covers about two more hectares and contains an arboretum of important trees (the survivors of a collection that formerly spread right across the historic lodge grounds).

Unlike most of the land around it, this part of Stoke Bishop is not in a Conservation Area. For some 70 years, the whole estate, which until recently had never been seen as a divided space, has been used by the local community and is designated an important open space. Nearly all the trees on the Stoke Lodge estate are subject to Tree Preservation Orders (TPO) which were placed on the trees in early 2012.

In the summer of 2018 Cotham School announced that it intended to erect a fence along the boundary of its leased land. They stated that they did not require prior planning permission to do so because they were exercising their statutory Permitted Development rights. After an initial dispute about whether the school could indeed use Permitted Development rights, in January 2019 work began to erect the fence.

It was at this point that the Bristol Tree Forum became involved after it became clear that the proposed route of the fence would pass through the root zones of a large number of important trees, many of which were the subject of a TPO.

The original plan – the fence passing through the root zones of many protected trees.

There then followed a protracted period of back and forth representations while we and the local community fought to get the fence relocated to avoid damaging the trees. This was partly successful. Where it was not, we were able to insist that the methodology for erecting the fence where it still passed through tree roots was modified to minimise damage. Even so, it took the constant vigilance of the local community and BTF representatives to ensure that Cotham School did not ignore the conditions placed upon it.

Setting aside the issue of the siting of the fence, our primary argument has always been that TPO law requires a prior planning application to be made (and approved) before any work is undertaken that could cause damage to TPO trees. Initially, the Council rejected this argument, effectively stating the Permitted Development rights trump primary TPO legislation. It also argued that, anyway, it could not proactively prevent damage to TPO trees, but had to wait until the damage has been done, which is, frankly, absurd. We continued to challenge these interpretations and, eventually, the Council conceded our points, though only after the fencing had been completed.

Things then appeared to return to normal,except that the community was now largely confined the unfenced areas around the boundaries of the site. As a result, the trees around the boundary are being exposed to heavier traffic through their root zones. We are concerned that this may have a long-term, adverse impact on their health.

Then, in August of this year, and without any warning, contractors arrived to lay cable ducting across the site so that video surveillance equipment could be installed. Using a mini digger they immediately set about driving over and cutting through the root zone of a TPO Common Ash growing on the boundary of the site. Other non-TPO trees (some privately owned) were similarly damaged.

It soon became clear that the contractors had neither been advised of the TPO status of the tree nor of the proper methods to use when working within tree root zones as set out in BS 5837 (Trees in relation to design, demolition and construction – Recommendations), or in the NJUG Guidelines for the Planning, Installation and Maintenance of Utility Apparatus in Proximity to Trees. This was despite the Council being aware of, and engaged with the school’s plans.

We lodged a complaint with the Council’s Planning department. As a result, enforcement proceedings were commenced and the school, whilst narrowly avoiding prosecution, was obliged to take remedial action to try to mitigate the damage caused to the tree. The council also felt obliged to remind the school of its obligations to TPO trees:

And this is a site where the trees are still under the ‘guardianship’ of the Council! What about those sites where the care is vested with the school?

Our concerns remain for the future health of those trees whose root areas had been invaded by the fence installation. We have also continued to express fears about other continuing threats to the trees arising as a result of other activities on the site. So far, our concerns have been ignored.

For example, continuing root compaction and branch damage is being caused to the Persian walnut growing by the gate close to the rear car park and to the trees growing beside the Parrys Lane entrance. This is the result of grass mowers and other service vehicles using these entrances to gain access to the site. We are told the access point has been moved to the Parrys Lane entrance, though that too involves vehicles passing over tree roots.

Driving over the walnut’s roots on the way to mow the playing fields

Historically, it looks like vehicles accessed the site from behind the Children’s Play Ground on the southwest of the site, so did not need to drive over any tree roots. The presence of the fence and lack of any gate there has now closed off that option.

The school’s contractors also continue to mow within the root zones of the two large Turkey oaks (BCC-77025 on the eastern end & BCC-7 7 059 on the western end) that grow inside the playing fields fence.

However, the Council and the school decline to address these issues saying that they have made adequate arrangements to safeguard the trees.

STOP PRESS – 4th January 2020 – since writing this blog, Cotham School has felled a TPO protected Elder (plus five others) on the Eastern side of the playing fields and poisoned it with Glyphosate. We have informed Bristol Council Parks and Planning Departments and asked them to investigate. They advise:

“The felled Elder trees were not included within or protected by the TPO covering the adjacent Sycamore tree.

It is very unlikely that roots from the Elder trees will have grafted with the roots from the Sycamore tree. Also translocation of herbicide between grafted roots is very unlikely.*

We are not aware of any plans to fell the twin stemmed Oak beside the white shed at the eastern end of Stoke Lodge Playing fields.”

But, when we asked Parks if these works were done with their prior knowledge and agreement, or if the department had approved the application of Glyphosate to the tree roots, or if they had seen the School’s Aboricultural Management Scheme, they answered ‘No’.

It seems that the school had complied with their obligation to get consent from the Council, their Landlord, but that the Council’s Education Asset Management team had failed to consult Park’s specialist tree officers about the plans.

More details can be found here.

Cotham School has issued these FAQs – 33 to 38 in response to this issue.

The fate of other educational sites

In the meantime, we have no idea if or how other schools are managing the trees on their sites, or if the Council is consulted when they do.

Even though, in most cases, educational sites are still on Council-owned land, the Council only needs to be told if the trees have a TPO or are growing in one of the city’s 33 conservation zones (or, we assume, if the Council’s lease with the school keeps the management of the trees in the control of the Council – as was the case at Stoke Lodge).

Given that Bristol City Council does not normally issue TPOs for trees on its own land, arguing that it is a good landlord and will look after important trees appropriately, it is unlikely that trees that have been handed over on other educational sites will have been protected by a TPO. Perhaps the council should now review its policy where it no longer manages trees growing on educational sites in light of this history.

Certainly it seems that new tree planting need no longer involve the Council. For example we recently observed that several newly planted trees at Cotham School’s main site had died. It was only when we noted that the dead trees were missing from the Council’s tree stock data for the school that we learned that they were no longer responsible for the trees on the site. We have now been told by the school that the trees were planted as part of a recent development and that the failure of these dead trees will be ‘rectified’ soon. Meanwhile, it seems that these new trees are no longer selected, managed or mapped as part of the Council’s wider tree stock strategies and that the existing trees on the site are no longer the Council’s concern.

Presumably, similar arrangements are happening across the city with other educational sites being left to make their own, ad hoc arrangements to plant trees or not. 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 of possible new planting sites might have been excluded from helping to achieve Bristol’s plans.

We are also 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 tree stock places upon them. As a result, they are likely to have to buy in (at our expense) ad hoc expertise, thereby possibly overlooking the wider strategic considerations that are needed when it comes to managing trees across the city.

This, coupled with the distinct possibility that well-meaning but unqualified Council officers may be making critical decisions about the welfare of trees on educational sites, makes for a very worrying situation.

*Here is a contrary view about using Glyphosate around and on trees – Tree pits: plants vs glyphosate

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:

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.
Other than in exceptional circumstances, hedges will no longer be acceptable as mitigation for tree canopy loss when applying BTRS.
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.

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

About Richard

Veteran pine threatened with destruction

There is a Black Pine (a Pinus nigra) in the back garden of 32 St John’s Road, Clifton, BS8 that its current owner wants removed. Its size suggests that it is probably at least 100 years old. If anything, and given the amount of management it has survived, it is more likely to be about 140 years old as it is very similar to the Black Pines on the Downs which were mostly planted around 1880. It has been protected by a Tree Preservation Order since 2005.

The tree is not easily seen from St John’s Road, but if you go round the corner to Chantry Rd and look north between the back gardens you cannot miss it. It is magnificent! 20 metres tall, with a stately crown around seven metres wide and a stem diameter of 85 cm.

St John's Rd Pinus nigra

The applicant no longer wants us to see the arboricultural report, based on an inspection of the tree in January 2017 (submitted with a recent application, but now withdrawn) which does not agree that the tree needs to go. Even though its previous management has been less than ideal with some resulting damage and there are the usual signs of ‘decay’ associated with the tree’s age, the tree is in ‘fair condition with no risk of imminent decline‘.

The surveyor goes on to observe that ‘The tree is a prominent specimen within the local landscape with high visual amenity. Being evergreen its prominence increases during the winter months, when the surrounding deciduous trees have lost their leaves.‘

He concludes ‘In my opinion the tree may be retained in the short to medium term…I recommend that it is inspected annually and after periods of extreme weather’.

Despite this, the owner wants it gone and has even persuaded some of their neighbours to support the application, with complaints of the fear of it coming down or losing its branches, and the inconvenience of fallen pine needles and possible blocked gutters.

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

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

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

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

Whilst this application to fell the St John’s Road pine is not, perhaps, strictly ‘development’ in the way that these policies intend, the principles they adopt must surely still apply.

A tree in a private space is not the exclusive preserve of those who happen to own it at any given moment, to stand or fall as whim dictates. We all benefit from trees, whether publicly or privately owned, and our planning law recognises that.

The St John’s Road pine probably has a CAVAT value of around £96,500, but this hardly begins to describe its true value to us – the delight it gives when first seen, the web of life it sustains in its branches, trunk and roots – never mind the carbon it has sequestered or the pollution we have dumped it has absorbed or the oxygen it has generated!

The pine may not be an ancient tree, but it is certainly a veteran tree, with all the characteristics that our national and local planning policies describe. Its value to the wider Bristol community has already been acknowledged by making it the subject of a Tree Preservation Order and requiring permission to be granted before anything can be done to it.

Bristol’s Mayor, Marvin Rees has challenged us to double tree canopy cover from around 15% to 30% by 2050. If we are serious about achieving this, then we must also resist these ad hoc attempts to remove trees like the St John’s Road pine.

The current planning application may be found by going to Welcome to Planning Online page, selecting Planning – Simple Search option at the bottom and entering 18/04039/VP in the last field at the bottom of the page. Press Search and , after a few moments, you will be taken to the Planning- Application Summary page headed ‘18/04039/VP | Austrian Pine (T1) per TPO No 940 – fell. | 32 St Johns Road Clifton Bristol BS8 2HG’. The documents, including various comments made to date, can be found under the Documents tab.

If you agree with us, and object to this magnificent pine being destroyed, please lodge your comments saying so on the planning website using Comments tab in the link above asap. We offer help navigating the Planning pages and with filling in your comments here.

The Eastgate woodland copse – Decision time

We have reported on this issue a number of times already – Trees under threat at the Eastgate Centre!, Trees under threat at the Eastgate Centre – Comments so far…, Eastgate woodland and Eastgate Woodland – Round Three, but the Eastgate Oak and the tree community it lives within is still threatened with destruction.

Eastgate Copse_5

The Development Control Committee will be meeting this Thursday – 21 June 2018 at 2 pm to decide whether outline planning permission should be given to remove the last vestige of an older woodland that once connected the Frome & Eastville Park with St Werburgh’s and the heart of Bristol beyond and redevelop this site. Small though the copse is, it still forms part of the green space in which we live and gives pleasure to many to many of those who pass by.

Here is the location plan:

Eastgate Oak Location Plan

This is what is being proposed – the living copse is gone and a few lingering specimens are left standing alone (for how long?) like exhibits in a museum, with new plantings (what species?) dragooned into neat lines like so many extras, but away from the main commercial activity which takes centre stage:

Eastgate Proposed Layout

The paragraph headed ‘TREES’ in Development Control Committee’s summary is instructive and says it all:

‘The application was submitted with insufficient survey detail to cover all the trees on the site including the understorey, and how they would be impacted by the proposed development. However, it is clear that one mature poplar tree would remain (adjacent to the existing retail unit on the western end of the site) and possibly one mature ash tree within the remaining area of landscaping following implementation of the scheme. It should be noted that the chances of this ash tree surviving are slim, as more than 40% of its root area would be removed. In the absence of an Arboricultural Implications Assessment or an Arboricultural Method Statement it is not possible to assess whether what is shown to be retained is in fact feasible. It is highly likely that much of the existing tree cover shown to be retained will be lost. The majority of the understorey would not survive the works proposed and any remaining understorey would be unprotected and more vulnerable to adverse weather. In short, given the proposed layout the conditions suggested will only be certain of protecting one mature tree. All the remaining trees will in all likelihood be lost. In terms of the ecological quality of the trees to be lost, the following additional comments can be added: The area of green infrastructure contains six ash trees that have been identified in particular as locally notable trees of age and are characterised as being ‘transition veterans’. This means that they provide important habitat due to their age and characteristics within a heavily built-up area where habitats are limited and they have the potential to become potentially important veteran trees for biodiversity in time. It should also be noted that this group of trees provides a significantly greater ecological benefit than a single tree as proposed. The group of trees also provides an element of future proofing the site, as if a single tree is lost due to the natural laws and forces of nature others remain that continue to provide ecological benefit.’ We agree!

If Bristol City Council is serious about its long-term goal of doubling tree canopy cover to 30% by 2050, it cannot allow this endless nibbling away of the little we already have, especially in places like the Eastgate Retail Park, already the victim of an older, unenlightened and merciless policy of development ‘desertification’.

Leaving just one or two specimen trees as a token concession to us ‘tree huggers’ really no longer suffices in the face of mounting evidence that the removal of trees, especially in urban environments, is more than just a question of utility and aesthetics, but impacts us and the world we live in immediate and direct ways by damaging our physical and emotional well-being and degrading the environment we depend on.

It is too late to submit questions, but petitions and statements may still be lodged as long as they are received by the Council at the latest by 12 Noon this Wednesday, 20 June. They can be emailed to democratic.services@bristol.gov.uk.

Statements will not be accepted after 12.00 noon on the working day before the meeting unless they have been submitted in advance to Bristol City Council but were not received by the Democratic Services Section. Anyone submitting a statement for an application will also be allowed to speak in support of it at the meeting.

Category: Tree Strategy

Our proposal for a new Bristol Tree Replacement Standard revisited

Like this:

The vital role of trees in urban development

Like this:

Developing a Tree Strategy for Bristol

Like this:

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

Like this:

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

Like this:

Council no longer manages trees on educational sites – Part I

Like this:

Changes agreed to Bristol Tree Replacement Standard

Like this:

Ancient and Veteran Trees explained

Trees and Planning

R L Bland

About Richard

Like this:

Veteran pine threatened with destruction

Like this:

The Eastgate woodland copse – Decision time

Like this:

Share this:

Like this:

Share this:

Like this:

Share this:

Like this:

Share this:

Like this:

Share this:

Like this:

Share this:

Like this:

Share this:

Like this:

Trees and Planning

R L Bland

Share this:

Like this:

Share this:

Like this:

Share this:

Like this: