A letter to our Councillors

Dear Bristol City Councillors,

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

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

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

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

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

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

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

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

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

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

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

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

Tree replacement and carbon neutrality

The UK aims to be carbon neutral by 2050. Bristol is more ambitious and aims to reach that goal in 2030. Both are massive challenges in which trees have been enrolled to play their part in mitigating the carbon dioxide (CO2) created by human activity.

Background

There are plans for extensive tree-planting.  The government pledged to plant 30 million trees a year, nationally. This a huge challenge partly because seedlings and land has to be found for these trees. However even when planted, these trees will take a long time to grow and extract CO2 from the air.  We in Bristol Tree Forum are concerned that not enough attention is given to the role of existing mature trees.  

Trees grow and add to their mass each year. Most of this mass is in the form of cellulose and lignin and about 50% of those organic compounds is carbon, obtained through photosynthesis using the energy of sunlight and CO2 from the atmosphere.  The rate at which mass is accumulated increases with age so whilst a 10 year old tree might put on a few kilograms a year, a 50 year old tree might add 50 kg.  So the older the tree the better for CO2 fixation. However mature trees are constantly under threat – from development for housing and industry, from home owners overshaded by large trees, from councils assessing maintenance costs and risks.

Here in Bristol, the Bristol Tree Replacement Standard (BTRS) is part of local planning regulations and specifies how many replacement trees are needed to be paid for by the developer and planted to mitigate the loss of mature trees. The BTRS is a very welcome and forward-thinking strategy, but is it enough to support the Carbon Neutrality goals? Should BTRS  apply also to council-owned and indeed privately owned trees for which no funded replacements are available?

The Bottom Line

In an attempt to understand how this standard works in practice, we have developed an on-line calculator to explore different scenarios.

Tree CO2 Calculator

The general conclusion from this analysis is stark:  it will take 25 to 40 years before the replacement trees are able to compensate for the loss of the mature tree.

The graph shows the scenario of the replacement of a mature tree such as a Maple with a diameter of 60 cm by the 6 trees as determined by BTRS which are faster growing but shorter lived such as Rowens.

Assuming that the original tree is felled, chipped and used as fuel in a biomass boiler (the practice in Bristol), the carbon stored in the mature tree is returned to the atmosphere within months of felling.  The replacement trees start to grow, but absorb much less carbon than the original mature tree would have done, so they take many years to catch up. In the case shown in the graph, it takes 35 years (ie, to 2055) before the new trees mitigate the loss of the original tree.

Modelling

A model of this scenario needs to take into account:

  • the rate at which different species of tree grow at different ages in different conditions.
  • the estimated mortality of the tree over time.
  • the calculation of a tree’s biomass from its girth for different species.
  • the relationship between the tree’s biomass and the amount of carbon stored.

There is a lot of uncertainly in these relationships, partly because of the paucity of data on urban, as opposed to forest, trees. Urban trees are under threat not only from natural processes and disease, but also from the vagaries of vehicles and humans. Planting sites are often less than optimal and urban trees have no support from the ‘wood wide web’.

The interactive calculator allows the user to vary the parameters of the model using the sliders. This allows the sensitivity of the overall outcome to variation in values to be tested. Different policy choices can also be explored and can be used in a predictive sense to determine the number of replacements needed to achieve a given carbon neutral date.

Summary

Documentation on the website explains the thinking behind the model in more detail, and the sources of data used. The model is still under development, in particular to make it easier to select conditions for different species and situations, and to improve the quality of the model itself. The research literature is extensive but often of limited applicability to urban conditions.

We would be grateful to receive additional or better sources of this information, and indeed any comments on the model itself at co2@bristoltrees.space.

Chris Wallace, Bristol Tree Forum

In Defence of Dead Wood

It was once believed that when a tree died, it was no longer of use. For decades, we have actively removed trees at the first signs of rot or fungal attack, felling them at the base and removing all evidence of their existence…

Our guest editor, Nick Gates, Naturalist, writes

Storm damaged trees are hastily sectioned for firewood or bio-fuel. Sometimes, we replace them with a new, younger version of themselves. It was thought that this in turn kept other trees healthy, and that the wider environment benefited as a result.

The fall of a tree opens up new opportunities…

But nothing is further from the truth. By removing this deadwood, we are stripping out a most vital layer of the natural world. Because when a tree dies, it isn’t actually dead.

As a tree grows, its core begins to die. Have you ever looked at a majestic old oak, its core completely hollowed out, and wondered how on earth it was still producing green leaves and fresh shoots? The reason is that only the outer layers of the wood, just below the bark, are alive. They transport all the water and nutrients that a tree needs to survive. Simultaneously, under the soil, a massive network of fungi around its roots help the tree collect all of the vital nutrients and minerals it needs. As the tree grows, the wood core, the growth rings left behind and superseded from previous season, slowly dies.

Left to fade away…

Over time, this core wood is slowly broken down by fungi. In the very oldest trees, the core is lost completely. Perhaps the most famous of these wood-feeding specialists is one you may well have eaten, the Shiitake mushroom. The fungi in turn are eaten by many species, from bacteria to nematodes, insects to mammals, whilst the rotten wood supports many more. Therefore, this soft rotting deadwood actually hosts a complex living food web.

St Andrews Park – The fallen Black Poplar

An oak tree supports over 350 different varieties of insect. But over half of these feed on dead parts of the oak tree.  Bats rely on deadwood cavities to roost, whilst feeding on many species of night-flying beetle that feed solely on deadwood. Redstarts require hidden cavities to nest, whilst searching for bark beetles and moths that grew up in the deadwood. Everything from blue tits to woodpeckers and wood mice to tawny owls rely on deadwood for some part of their existence. By the time an old tree falls completely, upended from its rotting root network, the wood may be dead but the vast diversity of creatures it is feeding are very much alive. 

When we strip out deadwood from a natural environment, often under an aesthetic tidiness premise, we aren’t just taking the wood away. We are slowly eroding the complex living food web that the deadwood feeds. The Bristol Downs has suffered from this for many years. We could have hedgehogs snaffling snails from deadwood retreats and spotted flycatchers nesting amongst the craggy cavities in gnarled out stumps. Animals just need food and shelter to thrive. By removing deadwood, we take away both. There are many ways of leaving deadwood that look aesthetic whilst appreciating the enormous ecosystem service it provides. Good signage can help explain this.

In a time of unprecedented ecological collapse, we must all do what we can to help the natural world. Leaving deadwood in situ is one of the easiest ways to do this. So please, next time you see a fallen tree, don’t look on it as an untidy addition to the landscape, but enjoy it as the next opportunity for nature to reclaim a part in our everyday lives.

@NTGates Feb. 2020

A Manifesto for protecting Bristol’s existing Urban Forest

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

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

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

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

We propose that

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

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

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

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

5th February 2020

Dear Bristol City Council Parks Department,

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

At the moment, our particular concerns are threefold:

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

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

The new vehicle access point at the eastern end.

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

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

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

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

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

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

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

Best Regards,

The Bristol Tree Forum

Council no longer manages trees on educational sites – Part II

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

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

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

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

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

We asked…

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

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

If so, please provide the following information:

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

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

The Council has responded to say…

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

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

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

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

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

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

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

What about protecting all the trees with a TPO?

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Our original concerns remain

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

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

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

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

Shocking treatment of Lower Ashley Road trees shows urgent need for Bristol Planning rethink

Bristol has declared a climate emergency. There is an urgent need for all council departments to re-think the way that they work.

At the time of writing, four of the trees in this image have been felled (two Norway Naples and two Indian Bean trees on a different plot).  The value of the five maple trees along Lower Ashley Road was calculated at £200,000 using CAVAT.  Local residents are desperately trying to save the three remaining maples.

This blog discusses six changes that are desperately needed to protect trees on development sites.

  • Planning Decisions regarding important or TPO trees should be considered by committee and not delegated to one officer.
  • It is practically impossible for local residents and other stakeholders to wade through all planning documents online. Planning Officers must highlight important tree issues and have a duty of care to act positively in favour of trees.
  • Bristol should implement policies to retain trees on development sites in the way that has been done in London, Oxford and elsewhere. This includes enforcement and a presumption to retain trees at the edge of development sites.
  • An emergency number to address immediate tree felling issues. 
  • It is a false choice to say that we can either have social housing or trees. With clever designs, we can retain existing trees and have better social housing.
  • Replacing felled trees, even when applying the Bristol Tree Replacement Standard, is second best to retaining existing large urban trees. We get the benefits from existing trees now – we have to wait decades for their replacements to grow.

Over the last six months there have been half a dozen articles in the local press and now one Guardian article about the shocking planning decision to allow removal of five Norway maple trees with Tree Preservation Orders (TPOs) on Lower Ashley Road, one of the most polluted streets in Bristol. There have been two meetings with the mayor who also visited the site and there is now a vigil by protesters on the site: police have been called on several occasions. All this indicates a planning process that has marginalised local residents and failed to take into account the value of the trees.

The Bristol Tree Forum appreciates the efforts by Mayor Marvin Rees to try and resolve the situation after the event. He visited the site and then convened two meetings in City Hall which he chaired. We have been impressed by his serious engagement and the way that he has brought all the interested parties into the room and handled the discussion. But, as we think he would agree, this is the wrong way around. Discussions such as this should happen before the planning decisions are taken so that there is community engagement in the decision making.

Planning Decisions regarding important or TPO trees should be considered by committee and not delegated to one officer

That we have got to this stage shows a serious failure of both Bristol City Council Planning policy and its implementation. The decision to remove the trees was taken in 2015/16 by one planning officer as a reserved decision. It did not go for to the Planning Development committee for a considered decision. Looking over the documents it doesn’t seem that any time or thought was given to the trees. The Arboricultural Report provided by the developer does not even state whether the trees had TPOs, and indeed there is no discussion of the TPOs in any of the documents in that planning application, with the only mention on the “constraints” page. In 2015, The Bristol Tree Forum commented in opposition to the proposal but even the BTF was unaware that the trees had TPOs. Whilst BCC insists that the decision was “valid”, without a mention of the TPOs there was insufficient information to allow intelligent consideration of the proposal, so we question that decision. Sufficient information for intelligent consideration is one of the fundamental principles of a “proper consultation” as decided by Lord Woolf*. The first mention of the TPOs in a document is in the Officer’s Report outlining the delegated decision. 

Unfortunately this is not an isolated failure: trees all over Bristol are being unnecessarily sacrificed as a result of applying ideology from the 1960s. For example a single planning officer gave the green light for the removal of some 25 trees on the Redland Girls School site, in a conservation area, despite the fact that the removal is purely for landscaping.

Redland Green Trees: damage to tree roots caused by driving construction vehicles over them can result in the eventual failure of the trees. In a failure of planning, no root protection zones or Arboricultural Methods Statements were ever established for these trees, despite permission being given for the construction company to store materials on Redland Green.
It is practically impossible for local residents and other stakeholders to wade through all planning documents on line.  Planning Officers must highlight important tree issues and have a duty of care to act positively in favour of trees

Important tree issues need to be highlighted and openly discussed during the planning process. Planning Officers already implement policy regarding flood risk, traffic management and other construction matters. The Bristol Tree Forum is asking that tree protection is included too as is done in other local authorities (Examples are Oxford and Islington, below). In addition, trees on or near active development sites must be properly protected.

We see applications with no information on the Bristol Tree Replacement Standard calculations, or obviously incorrect information being supplied. Documents such as these should be rejected by the planning officer.

Redland Green Trees. Permission was given for this TPO Ash tree on Redland Hill to be removed (in addition to several others on the site) to allow articulated lorries to enter the building site. In the event, the gateposts were never widened, articulated lorries didn’t enter the site as this would have been extremely difficult even with gate widening and the tree was retained until Aug 2019, when it was removed anyway.
The Indian Bean trees growing on the next-door site on Lower Ashley Road before they were felled. Together with the Maples nearby, they formed a welcome green oasis in an otherwise treeless urban setting.
All that remains of the Indian Bean trees which were chainsawed following rejection of an application that was refused because the trees were felt important and merited TPOs.  The trees were removed anyway. We are trying to find out why the trees were not then protected with TPOs.
An emergency 24-hour number to address immediate tree felling issues. 

Bristol is at risk of becoming known as a Mad Max world now that unqualified people are wielding chainsaws from ladders above passing pedestrians with no enforcement consequences, often on public holidays, sometimes in the evenings and even at night. A proper approach for addressing this problem needs to be developed in collaboration with the police. It is unfair to send a single tree officer on their own to deal with issues of public order. Multiple phone calls and sometimes hundreds of emails to numerous council departments very quickly overload already overstretched council officers. It is no good passing the buck to the Health and Safety Executive. Therefore we need one emergency Bristol City Council number.

Lower Ashley Road.  Bristol City Council urgently needs to come up with a procedure to address dangerous activities by unqualified people using chainsaws over pavements and roads.
A Maple with the arrow sign captioned ‘here’ pointing at a partially sawn limb : Following complaints over an entire week, this dangerous almost severed branch was only addressed after an article appeared in the Bristol Post.
Trees growing at Cotham School were removed by Skanska (2008) in the afternoon before Good Friday when no enforcement action could be taken.
Bristol should implement policies to retain trees on development sites

Where possible we should build developments around existing trees. There should be a presumption to build around existing trees and particularly to retain trees at the edge of development sites. 

The developer’s arboricultural report for Lower Ashley Road states that “In order to retain the trees within any new scheme, the front of any new building will need to be sited a minimum of ten metres from the existing site boundary”. We have heard this assertion stated by developer and planner as “the ten metre rule”.

There are many examples where mature trees are retained close to new buildings, in London, Oxford and elsewhere. This must become commonplace in Bristol too.  A Trees and Design Action Group article describes the construction of the Angel Building (Islington, London) around existing mature trees. No cowboy chainsawing there. Instead extreme care was taken in a project that was led by landscape architects. For example:

Deliveries needed to be conducted on a daily basis. To enable this, the Tree Protection Plan (TPP) and Arboricultural Method Statement (AMS), developed by appointed tree specialist JCA, in coordination with the project landscape architect and the council tree officer, proposed the use of a porous load-spreading cellular confinement system (Geoweb) braced with timber frames.

All existing trees were irrigated during the two-year construction period following a sporadic pattern imitating rain. Because irrigation was fed with calcium-rich London tap water, the system was fitted with filters to avoid increasing the soil pH.

The Clifton Suspension Bridge visitor Centre (Alec French Architects) in North Somerset, not Bristol, is within 2 metres of an important tree.  The roof line has been cut away to accommodate a branch.
Aurora Building, Counterslip, Bristol.  Energy efficient, outstanding architecture and built extremely close to an existing plane tree.
It is a false choice to say that we can either have social housing or trees. 

Although the 2015/16 planning approval that is being used to justify removal of the trees was for student accommodation, the current proposal, still under consideration, is for social housing that Bristol desperately needs.  We are surprised that, despite this new undecided application, the developer is still able to undertake work under the old approved application which they no longer intend to pursue.  Shouldn’t the slate be wiped clean so we have a chance to revisit the whole plan with the trees still in place rather than be forced to decide without them?

The developer, planners and others have presented a false choice stating either we retain the trees, keep the site derelict and leave 28 families homeless, or we remove the trees. 

These trees are right on the edge of the development site. With clever designs, led by a landscape architect (not even apparent that one has been engaged for this project), and carefully constructed foundations (e.g. screw piling), the developer could build close to the existing trees. The result? Better social housing which benefits from existing green infrastructure and provides a more pleasant environment with some protection from the noise and pollution of this busy road.


  • Lord Woolf MR in R v North and East Devon Health Authority, ex parte Coughlan [2001] QB 213, [2000] 3 All ER 850, [108] as follows: whether or not consultation is a legal requirement, if it is embarked upon it must be carried out properly; to be proper, consultation must be undertaken at a time when proposals are still at a formative stage; it must include sufficient reasons for particular proposals to allow those consulted to give intelligent consideration and an intelligent response; adequate time must be given for this purpose; and the product of consultation must be conscientiously taken into account when the ultimate decision is taken.

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.

Redland Hill street trees felled by the Council. Why?

Until a few weeks ago there was a lovely informal stand of trees along Redland Hill, which is a busy road that I walk up twice a day to get to the Downs.

As it used to look – Google Street View – July 2018

Rush hour stationary traffic belches out pollution and the trees provided some respite.  I have watched over the years as several of the old beech trees were removed.  They were probably once part of a beech hedge that predates the existing buildings (and the wall): now only one is left.  Instead, an informal collection of ash and other trees grew in their place.  This was a great place to see Broomrape, a parasitic plant that grew at the base of some trees.

How it now looks…All gone – just one lonely beech and some street furniture left to improve the view.

There was no consultation of any kind with the community. One day the trees were there, the next they were gone. Without any involvement from the Bristol Tree Forum, the local councillor or the local community, we can only guess why the trees were removed. Perhaps it was concerns about the nearby wall.  A careful examination shows that there are no obvious cracks, even close to the one remaining beech tree.  Was a proper engineer’s survey done? In days gone by a Bristol City Council Tree Officer defended a tree, similarly close to a garden wall, that the owners wanted to cut down, even obtaining an engineer’s report. Even if there were substantial damage to the wall, other options were possible, such as thinning out the trees (only some were marked with green paint) or laying them as a hedge as was recently done in Redland Green.

…just sawdust, rubbish and some ivy (now hacked down), nothing else.

Of course the removal may be for a different reason. Maybe what the developers really wanted to do was to create views for their flats and successfully put pressure on the council? Perhaps the pavement will be widened?  Or perhaps the area will be dug up for services. I don’t think the removal of trees was in the planning application.

J

At this time, with the threat of Ash die-back disease we should be looking to keep healthy ash trees in case by chance they turn out to be the ones that are resistant. Cutting down healthy ash trees is misguided.

The money that was spent cutting down these trees should have been used for planting new street trees, something that Bristol City Council says it has no funds to do. I’m guessing more money will now be spent to tarmac over the area where the trees once were. 

Bristol City Council should have thought differently. For example, it should have enforced a root protection area for the last remaining beech tree. This was apparently not done and I guess we will see that last tree fail in the next ten years.

At present, Bristol City Council refuses to consult over tree felling decisions, despite requests from the Bristol Tree Forum for a decade. It is almost as though the council thinks there are no inhabitants in the urban forest and that they always know best. Unilateral decisions such as this show how important the government’s proposal is to require local authorities to properly consult before removing street trees

Bristol has an ambitious plan to double its tree canopy by 2050. Yet all over Bristol, on an almost daily basis, tree canopy is being lost – for multiple reasons. Just in the local area, about half a dozen really large trees have gone and the canopy cover has decreased. We did manage to get one new street tree, in the middle of Redland roundabout but it took a four year battle and the help of our local MP to get it planted. Trees are lost very gradually in our bit of Bristol and are often not replaced.  So the change in canopy is not obvious. Fisheries biologists have coined the term “shifting baselines”, where each generation sees only minor negative changes. But the effect over a long period is substantial.

As Professor Corinne Le Quere has said, “actions to tackle climate change have to penetrate all the decisions that we take in society”. We are hoping that we can get this point across to the decision makers in Bristol City Council.

The Bristol Tree Forum will now be campaigning for these trees to be replaced.

Vassili Papastavrou.