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.

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 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.

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.

The TPO trees and canopies

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.

Digger in amongst the TPO Ash roots

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-77059 on the western end) that grow inside the playing fields fence.

The eastern Turkey oak

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.

Before the Elders were felled
The aftermath

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:

  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.

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.

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.

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 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.

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.

Planting and replacing Bristol’s street trees with Section 106 money

There are some 38 s.106 agreements worth more than £400,000 available just for planting trees in Bristol.

BCC Area 01

Section 106 (of the Town & Country Planning Act 1990) agreements are private agreements made between local authorities and developers. Some Section 106 agreements are specifically made to replace trees lost because of development. In Bristol, these agreements are made under the Bristol Tree Replacement Standard (see pages 20 & 21). They often also require that trees be planted within a one-mile radius of a development site. The current total value of these funds is more than £400,000.

There are also another 27 agreements that relate to ‘Parks & Open Spaces’ valued at more than £450,000, some of which might also be used to plant trees, but subject always to agreement with Bristol Parks Forum and other local ‘green space’ community groups.

Here is a summary of the current tree-specific agreements grouped by Ward and the new BCC Administration Areas:Ward S106 fundsBackground Notes

Of the 52,017public trees and tree sites managed by the council, a third are street trees. Across the city there are 944 vacant tree sites, 542 of which are places where street trees once grew. Bristol Tree Forum is negotiating to have these sites made available for sponsorship. The remainder of these tree sites are in housing estates, parks, cemeteries, amenity areas and many other green spaces.

None of these sites is available to sponsor but there are currently another 707 sponsorship sites, of which 246 are in streets. These figures constantly change as trees felled are added and sites sponsored are removed. Figures for sponsorship sites where a sponsor has come forward, but the tree has not yet been planted are not published.

These sites could also be funded by Section 106 money. This makes 1,651 sites across the city where trees could, potentially, be replanted. Of these some 1,198 lie within one or more of the areas specified by these Section 106 agreements and 417 of them are on streets.

Replacing all Bristol’s lost trees using only Section 106 agreement monies would cost £765.21 per tree. Planting trees in new sites (sites where there was never any tree) may be more expensive: £3,318.88 per site if the pavement must be lifted, services are disturbed, and a specially designed tree pit installed. If all Section 106 agreement funds were used to replace just lost trees, then some 540 trees could be replaced – 45 per cent of the total number of sites available.

Figures available for tree planting on streets show that 608 street trees were planted between 2013 and 2018, an average of 122 per annum (We are happy to provide the reports and data upon which this table is based on request).Trees Planted tableWe have now been able to establish that the Council felled 1,304 trees over the last three years. We have not yet been able to find what sort of trees they were or where they we located, but it is likely that most were located on streets. 363 street trees were planted over the same period.

* This figure constantly changes. As trees are felled, they are removed from the main BCC asset register. The site disappears until a new tree replaces (if it ever does) the one lost. Trees are usually planted during the winter months when most trees are dormant.

Here is a pdf of this blog.

Help shape Bristol’s Tree Strategy Action Plan – join the iTree Bristol tree survey

Come along and find out about the iTree Project training day between 10 a.m. to 12.30 p.m. at Ashton Court next Sunday 13th May.

iTree Bristol is a new project providing a great opportunity to be personally involved in a campaign to care for the Bristol’s existing trees and woodlands and to plant many more of them all over the city.

The plan is to survey around 200 randomly selected plots across the city. In this way we will have a better understanding of the structure of the city’s urban forest and the many benefits it brings us – reducing air pollution, capturing carbon, reducing rainfall runoff.

Internationally recognised, i-Tree Eco is being used by cities and towns across the UK to help inform their tree strategies. The results of our iTree Bristol survey will inform the forthcoming plans for our Tree Strategy Action Plan, setting out our goals and priorities for increasing our tree canopy cover and developing and funding our urban forest and its trees into the future.

iTree Bristol needs volunteers to help run the survey. You don’t need to be an expert. All you need is an interest in trees and have time to help with a small number of surveys over this summer when our trees are in full leaf and at their best. Forest of Avon Trust will provide training and support.

Come and join in

If you would like to join in, please complete the form below and email it to Forest of Avon Trust to register your interest. They will be in touch with more information about the event.

Complete the iTree Bristol Volunteer Contact form to volunteer!

iTree Bristol  is supported by the Forest of Avon Trust working with Bristol City Council, the Woodland Trust and Bristol Tree Forum. This core group will also be working with organisations and individuals across the city to produce Bristol’s Tree Strategy Action Plan.

As plans develop, more information will be provided through the our web sites and Twitter accounts –  and .

And don’t forget to sign the Tree Charter…

 

Tree_charter__logo

 

Tree Canopy Cover – a strategic solution?

A recent study* has used i-Tree Canopy^ (a free-to-use tool developed by the USDA Forest Service) to survey the tree canopy cover (TCC) of 282 towns and cities in England.

TCC, also called ‘urban canopy cover’ or ‘urban tree cover’, has been defined as the area of leaves, branches, and stems of trees covering the ground when viewed from above. It is an easily accessible measure that can be used to estimate the percentage of tree cover that any urban area enjoys.

It is now internationally accepted that properly managed forests and trees in urban environments make important contributions to the planning, design and management of sustainable, resilient landscapes – they help make cities safer, more pleasant, more diverse and attractive, wealthier and healthier.

Research also suggests that even moderate increases in canopy cover within cities can aid adaptation to the adverse effects projected under a changing climate. However, a baseline TCC value for many of the UK’s towns and cities is unknown.

Nor is it known whether canopy cover is changing and, if it is, whether it is increasing or diminishing. There is also a knowledge gap when it comes to knowing the numbers of trees in towns and cities, or their species, age composition and health. The level of canopy cover required to deliver meaningful benefits in UK towns and cities is also unknown, though there is some evidence to suggest that it is in decline.

This study* has now gone some considerable way to answering these questions and revealed a wide range of baseline tree canopy cover across the country – from a TCC of 45% in Farnham to just 3.3% in Fleetwood; with a median TCC of 15.8% and only 132 (47%) of sampled areas exceeding this.

Bristol, for example, ranks 176/282 samples if the 14% TCC identified in a study undertaken by Bristol City Council in 2011 is used. If the 18.6% cover estimated in this recent study is used (the study only looked at TCC in the urban land classes, rather than at the whole administrative area covered by BCC), then its TCC is above average and it would rank 83/282 samples. This suggests that “…boundary choice can impact TCC results and should be driven by the overriding question: ‘what is the tree canopy cover in the urban land classes of a given local authority?’, compared to ‘what is the tree canopy cover in a given local government jurisdiction?'”‘.

Doick et al – i-Tree Canopy Assessment urban area mapped

Bristol also has the added benefit of having already surveyed many of its public trees, albeit some eight to ten years ago. This treasure-trove of data has been collated and augmented with other data we have collected to make a dataset of nearly 67,500 individual trees (though just 2.4% of predicted TCC) and made available to all via the Trees of Bristol web site.

Conclusions drawn by the study

A TCC target that is city-wide and not targeted at specific wards or land-uses poses a number of challenges. It can be delivered in such a way that does not optimise or diversify benefit delivery. For towns and cities that have a green belt (or similar designation), planting schemes can be targeted within this land. However, with comparatively lower populations than the urban centres, planting here offers fewer benefits on a per capita basis.

Canopy increase targets could equally be met by preserving the existing tree stock and allowing natural growth. As the canopies increase so will total canopy cover, although such increases will be constrained by tree loss/removals, natural wastage and damage by pests and disease.

Such an approach, however, also fails to address social equity. Targets based on land-use-based assessments or ward are more likely to align the provision of ecosystem services with indicators of social inequity. It will be important that such approaches are underpinned by a robust baseline and a commitment to repeat canopy cover surveys using a consistent approach.

Species diversity and placing the right tree in the right place are important considerations when planting to achieve a TCC increase as these allow resilience to be built into the urban forest. Knowing the composition of the existing urban forest in terms of species and age structure, condition and appropriateness to location (and therefore life expectancy) can inform such decisions. Given that private ownership of trees can be as little as 24-35% in some cities, but as high as 71-75% in others (Introducing England’s urban forests), TCC baselining studies should be complemented by a field study.

With the wide range of considerations and stakeholders involved in urban forest management, TCC targets should be set both within local planning policy and within a formal urban forest management strategy.

Targets should have a target date, an action plan and a commitment to monitor, review and update. The policies should inform on which tree species to plant. They should also prioritise wards and/or land uses and should protect the existing tree canopy by enforcing best practice, codes of practice and statutory controls in the care, maintenance and protection of trees. Given that the average lifespan of a typical urban tree is estimated to be 32 years, changes in the age profile of the urban forest should also be modeled to at least 50 years distant in order to understand and plan for the likely impact on total TCC of tree planting and loss.

Any strategy will need to focus on partnerships with institutions and on guidance advising residents how they can best protect and look after their tree stock, schemes to assist in management and maintenance, and support future tree planting amongst the different ownership groups.

Finally

City-wide tree canopy cover is a useful indicator of the extent of tree presence across a city. Its assessment can be simple, fast and highly reproducible. Repeat observation could be a cost-effective means of monitoring tree populations, setting targets and tracking effectiveness of planting programs.

The results of this study suggest that:

  • an average TCC of 20% should be set as the minimum standard for most UK towns and cities, with a lower target of 15% for coastal towns;
  • towns and cities with at least 20% cover should set targets to increase cover by at least 5% (i.e. above the ±2% tolerance of i-Tree Canopy) within 10 to 20 years (depending on what is achievable against their baseline); and, targets and strategies for increasing tree cover should be set according to the species, size and age composition of the existing urban forest, based upon a ward/district level and land-use assessment.’

We at BTF commend and recommend this very helpful and timely study.

* Doick, K.J., Davies, H.J., Moss, J., Coventry, R., Handley, P., Vaz Monteiro, M., Rogers, K., Simpkin, P. (In Press). The Canopy Cover of England’s Towns and Cities: baselining and setting targets to improve human health and well-being. Conference Proceedings of TPBEIII. Urban Trees Research Conference. 5-6th April 2017. Institute of Chartered Foresters, Edinburgh.

i-Tree Canopy