Hundreds of trees threatened at Hengrove Park

The Council’s Development Control A Committee will meet at 6 pm on Wednesday, 16th October at The City Hall to decide the fate of more than 850 parkland trees. We have submitted this statement:

Hengrove Park is just under 51.5 hectares in area and contains 545 mapped trees comprising 37 species. There are many more unmapped trees also growing there.

These trees have a Capital Asset Valuation of Amenity Trees (CAVAT) (One of a range of tools recommended by The Trees and Design Action Group (TDAG) for valuing trees and green infrastructure ) value of at least £5.2 million, a valuation which is based on measurements of the tree diameters made at least 10 years ago. In the meantime, the trees will have continued to grow, making the current CAVAT value even greater.

The Bristol Tree Forum (BTF) was not consulted about the proposed development of this site, which will result in the removal of hundreds of these trees. Many local residents have submitted comments expressing concern about this aspect of the development.

BTF’s starting position is that trees should not be felled if at all possible, and that everything that can reasonably be done to avoid this should always be considered before a felling decision is made. If trees must be felled, then compensatory planting should be undertaken in such a way that there is no net environmental loss.

In order to implement the Council’s recent declaration of a climate emergency, increase net biodiversity and help double tree canopy cover, this development needs to be redesigned to fit around the existing trees, not remove them.

The current documents make various assertions as to the numbers of trees to be lost and the calculations for replacements required under the Bristol Tree Replacement Standard. This can be addressed by the imposition of our proposed planning conditions (see below).

Implementing Bristol’s declaration of a climate emergency

Bristol City Council was the first UK local authority to declare a climate emergency. As Professor Corinne Le Quéré FRS has said, “Actions to tackle climate change have to penetrate all the decisions that we take in society.”

The Government’s 25-year environment plan states that it will strengthen existing requirements for net gain for biodiversity in national planning policy. As it is, we have calculated (appendix 1) that this scheme, if permitted, will result in a net environmental loss of just over £3.65 million – Our CAVAT valuation of the trees potentially lost to this development is nearly £3.8 million (point 8 of Appendix 1). If the figures for tree felling relied on by the Council are accepted, then the figure will be much higher.

Bristol also has ambitious plans to double its tree canopy by 2046. If it is to implement this, and is serious about its declaration of a climate emergency, and wishes to achieve a net gain in biodiversity, then developments like this need to be radically rethought so that we build houses around existing trees rather than felling them, thereby avoiding or at least minimising the loss of our precious existing tree stock.

In addition, we note that the plan is also to remove a row of black poplar trees, a key landscape feature of the site. This is contrary to Policy BCS9 of the Bristol Core Strategy.

Conflicting figures for the calculation of replacement trees under the Bristol Tree Replacement Standard

The figures for the number of trees to be felled differ within the various planning documents and the BTRS calculations are confusing. We address this in detail at Appendix 1.

A technical note (23rd September 2019) identifies 859 trees to be felled, to be replaced by 1,280 new trees.  Elsewhere in the note, a table lists the values given for each BTRS category, which come to a total of 181 trees to be felled with 294 replacements. The table produced at paragraph 5.5.17 of the Environmental Statement Addendum gives different values again – 674 trees to be felled with 986 replacements.

These serious discrepancies need to be resolved before the Committee can form any clear idea of the impact of this development on the park’s trees. We propose a number of planning conditions, set out below, to ensure that the BTRS calculations are correctly made.

We are also concerned to read the Tree Officer’s report which states “As a number of the proposed trees are extra heavy standards it is considered that these can count as three new trees and overall the BTRS is met”.  This is simply wrong. The BTRS contains no such protocol.

The care of replacement trees after planting

Many trees that have been planted as a result of large schemes like this fail because they are not properly looked after.  A recent example is the Metrobus scheme, in which large numbers of trees were planted but have failed, probably due to lack of watering or, in some cases, vandalism. As far as we are aware, Metrobus (the developer) has not given any indication that it will replace these lost trees.

In our view, any replacement planting must be done under British Standard BS8545:2104 (Trees: from nursery to independence in the landscape) with a detailed specification in these terms being made a condition of the development. This should include a clear obligation placed on the developer to replace trees which fail within, say, five years of planting.

Planning conditions requested by BTF

The information that has been used to undertake the BTRS calculation is both incorrect and two years out of date.

If the Committee allows this proposal to proceed despite this, we request that the following planning conditions be imposed:  

  • No felling and replacement of any of the trees on the site should take place unless and until an updated survey is undertaken and the actual numbers and DBH values of all the trees (both individually and in groups) identified for felling are ascertained.
  • The BTRS replacements required are agreed with the Bristol Tree Forum and a Planning Arboricultural Officer.
  • All tree planting conforms with British Standard BS8545:2104 (Trees: from nursery to independence in the landscape).
  • A condition of the development includes a clear obligation on the developer to replace trees which fail within, say, five years of planting.

Here is the full statement we have submitted – BTF Full Statement, plus the one page summary that we have been asked to submit for the committee meeting – BTF Summary Statement.

We also link to the Statement submitted by Treespect which we wholly endorse.

You can link to the Council’s application here, via our BTF Planning Portal – 19/02632/PB.

Appendix 1

The application of BTRS requires that the trunk diameter (called Diameter at Breast Height, or DBH) of each tree identified for felling be measured. This measurement is then used to calculate the number of trees to be planted as replacements for the felled tree using this table:

This planning application is based on a tree survey that was undertaken some time in November 2017 and set out in an Arboricultural Impact Assessment dated May 2019. Part of this survey was updated in Appendix C of an Environmental Statement Addendum dated 4th September 2019. However, the DBH values have not been changed, so these values are now two years out of date. The trees will have grown in the meantime.

There is also a technical note dated 23rd September 2019 which identifies 859 trees to be felled, to be replaced by 1280 new trees. The following table is produced on page 5 of this note:

However, the values given for each BTRS category come to a total of 181 trees to be felled with 294 replacements, not the totals shown above.

The table produced at paragraph 5.5.17 of the Environmental Statement Addendum gives different values again: 674 trees to be felled with 986 replacements. However, this excludes the number of individual trees within groups G1, G354, G355, G380 and G417, so it is impossible to make any like-for-like comparison.

Having collated the two surveys published in the Arboricultural Impact Assessment and in Appendix C of the Environmental Statement Addendum into a spreadsheet (click here to download), we note the following:

  1. 533 individual trees have been identified and their DBH values recorded. Of these, 167 are identified for felling.
  2. 43 tree groups have also been identified, 13 of which are listed for removal or part removal.
  3. Save for groups G347, G347b and G347c (which have 5, 24 and 7 trees respectively in them) the number of trees in each group (or the number of trees to be removed) is not given.
  4. Save for groups G347, G347b and G347c (which have 5, 22 and 7 DBH values respectively listed), only one DBH value is given for each group.
  5. If we assume one tree per species listed for each unnumbered group,[1] then 228 trees in total are identified for felling.
  6. This produces a BTRS value of 294 replacement trees (again, if we assume one tree per species for each unnumbered group and that all these trees have the same DBH[2] as that given).
  7. Of the trees surveyed, 176 are given an ‘Estimated Remaining Contribution’ (life expectancy) of 10+ years; 46 have a life expectancy of 20+ years; and the remaining six have <10 years of life left. These 10+ and 20+ values are meaningless as they give no upper range. The CAVAT approach is to set life expectancy within these bands:
    • <5 years.
    • >=5 & <10 years.
    • >=10 & <20 years.
    • >=20 & <40 years.
    • >=40 & <80 years.
    • >=80 years.
  8. Applying a life expectancy of between 40 and 80 years and a CTI factor for Bristol of 150,[3] we calculate that the 228 trees we have identified for felling have a CAVAT value of £3,784,282. Using the same factors, the 294 BTRS trees (assuming standards with a DBH of 5 cm) would have a CAVAT value of £134,184, a net environmental loss of £3,653,652.

[1] We accept that each group probably contains more trees than our working assumption.

[2] We accept that the DBH values will vary from tree to tree.

[3] A CTI factor is applied to the base CAVAT value to account for population density. Bristol has a population of 459,300 and a land area of 10,970 hectares. This gives a population density per hectare of 41.9 and so a CTI Index of 150.


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.

Urgent help needed to water new trees

Lots of newly-planted trees on The Downs and elsewhere are suffering from lack of water in this unusually dry weather.  Many trees are dying.

The soil around the roots of each tree was so dry that (despite the recent rain) it would now take a lot of water to become hydrated.  Your help is urgently needed to water any of these trees that you see.  Even if they look nearly dead, with a lot of water they may come back to life.  These trees were paid for by members of the public and local organisations.

A number of people have raised concerns and Bristol City Council has said that it will now water each tree twice a week.  Some are in good shape – one sponsor has been watering her own tree.

IMG_0446
Just about hanging on…

Last year, the same thing happened and after six months of raising concerns with Bristol City Council, they said that last year’s problems would not happen again and watering would be sorted out for this year.  Much of the cost of planting a new tree is to cover sufficient watering for the first couple of years.

Clearly, it is a terrible waste of trees, time and effort and upsetting for the sponsors for the trees to die.  The Bristol Tree Forum  will keep raising this problem so that future sponsors can be sure that their trees thrive and that dead trees from this year and last year’s plantings are replaced.  A proper guarantee needs to be obtained for the future.

IMG_0454
Too late – these trees on Redland Green are dead

If you know anyone who sponsored one of these trees alert them and encourage them to water their own tree.  If you see a new tree that is dead or dying please email us a location and photo.

Vassili Papastavrou

Bristol Trees in Crisis III – BTF Emergency Meeting – 6.00 to 8.00 pm, Tuesday 4th July, Bristol City Hall

You are invited to a meeting at Bristol City Hall on Tuesday, 04 July 2017 between 6 and 8 pm.

The meeting will discuss and consider:

  • The Council’s consultation on its recent decision to stop maintaining street trees in the city.
  • The consequences of this should the decision not be reversed.
  • What solutions to this threat to Bristol’s street trees we can to offer.
  • To plan a way ahead.

We hope to hear from speakers from Sheffield, where the Council’s careless decision to outsource highway maintenance without considering the impact on its urban tree cover has and continues to result in the destruction of Sheffield’s magnificent street trees.

We also hope to hear from Birmingham Trees for Life, where, despite a similar decision ten years ago, they are still able to protect, maintain and plant trees in public open spaces.
More information to follow, but make it a date now!
In the meantime, please make your thoughts known by contacting your local Councillor and emailing the Mayor.
You can also Contact us here at Bristol Tree Forum to register your support and offer to help defend Bristol’s public tree spaces.
Please spread the word and forward this blog to others interested in saving Bristol’s trees.
AND FINALLY – Sign our petition!

Trees under threat at the Eastgate Centre – Comments so far…

Many thanks to all of you who have lodged comments on this application (nine so far). Here is one great example:

  1. This proposal flies in the face of the objective of the city council to double tree canopy cover in a generation.
  2. There is clear evidence that climate change is in part being driven by the city heat island effect. Bristol is already two degrees warmer than the surrounding area. A mitigation of this is to ensure that all car parking areas are shaded by trees- and not simply by a perimeter screen, but the use of suitable trees 20 metres apart to cover the entire area. This particular complex already has huge areas of unshaded car parking, and the proposal would only increase this.
  1. The Frome Valley is a key feature of the city’s biodiversity. It is one of a series of wildlife corridors that form a key feature of the attractiveness of the city to humans. This corridor is increasingly being eroded by development. As the River Frome has a huge water catchment area, which is increasingly being developed, creating much greater and faster run off, it floods rapidly and frequently. The fact that flood water is now diverted at the site of the Eastgate shopping centre into the northern stormwater interceptor will not prevent future floods upstream.
  1. Visually this remnant woodland of the Frome Valley is crucial it counteracting the utter ugliness and dreariness of the developed site. This of course originates from the original use of the site as a football and greyhound racing stadium. Bristol deserves better.
  1. What is desperately needed throughout this site is more trees being planted on the land owned by the various firms in the area, and not the destruction of the trees that by happy chance have survived.
  1. The wonderful veteran oak in particular, probably 300 years old, should become the centrepiece of a revival of this dreary area.

This is our earlier blog. Time is running out to lodge your objections. If you want to do so, please lodge your objections here in the Planning application comments section.

These are the Important dates:

Eastgate Trees3

Trees under threat at the Eastgate Centre!

Bristol’s trees are constantly under threat from development, especially when the commercial value of the land they grow on is so great and the public amenity value they offer is not thought worthy of consideration.

Here is (yet) another example.

An outline planning application – Number 17/01580/P – has been made to at the Eastgate Centre on Eastgate Road  for the demolition of the existing drive-thru restaurant. It will be replaced by new retail units with a health and fitness club above and a replacement drive-thru restaurant.

Part of this application will require the destruction and removal of a delightful stand of trees that grow on a triangle of land between the roundabout on Eastgate Road and the existing retail park. This is so that larger retail units can be built and goods vehicles can more easily gain access to the rear of the site. This is a plan of the trees affected.

Eastgate Trees

This is the proposal for what will be planted in their place – a souless echo of what is already there:

Eastgate Trees2

The Council’s own arboricultural officer has objected to the proposal. He advises:

“I have conducted a site visit and reviewed the supporting arboricultural documentation. The trees on site are located on the edge of the proposed development area and provide a significant screen to the already extensive retail development. The group of trees fall within 2 distinct age ranges, a mature group of ash, oak and poplar and a young understorey of secondary infill planting.

The mature trees are protected by TPO 282. The ash and oak are a historic remnant of a landscaped garden (Circa 1900) from the former gas works that occupied the site, the ash appear to of been managed as old pollards which have now grown out. They are historic trees with potential veteran tree characteristics that warrant the TPO status and must be retained. Due to poor management or lack of management the trees have a number of less than satisfactory defects associated with them that have in part been identified within the supporting tree survey from February 2015. The understorey planting appears to date back to the original development of the retail park, this understorey now has a more complex relationship with the larger TPO trees. They reduce the target area of people and property by the restriction of movement within this area and they also provide shade to the lower portions of the main stems which when considering the potential veteran tree characteristics offer significant ecological benefits. The management of this area for the benefit of the mature TPO’d trees would need careful consideration.

The supporting arboricultural survey is out of date and only provides basic survey detail that does not consider age and historic relevance of the TPO’d trees. The survey in not a full BS5387 report as required with DM17: Development Involving Existing Green Infrastructure.

The proposal seeks to redevelop the current Burger King site to increase the number of commercial units with associated HGV delivery bays to the rear.

This proposal would remove the vast majority of the historic TPO’s trees and associated understorey, This would be detrimental to the TPO status of the trees. The final design would be in constant conflict with the trees identified for retention leading to further applications to remove the tree following occupation of the individual units.

The Mature Oak T10 is a key amenity feature located in an elevated position over the roundabout at the gateway of the Eastgate centre; this is a TPO’d tree and no evidence has been provide to justify its removal.

I object to the proposed and would recommend refusal of the application on the grounds of a detrimental impact to the only green infrastructure on site and historic environment. Insufficient detail has been presented in accordance with BCS9, DM15 & DM17. There has been no consideration of the TPO status of the trees or their current or future management.

The arboricultural documentation is poor, out of date and insufficient to support an application, the tree planting plan produced to mitigate the loss of such significant trees has not considered the “Planning obligation SPD, Tree.” (Bristol tree replacement standard (BTRS). I hope you find these comments of use.

Matt Bennett Arboricultural Officer (Planning) City Design Group – Place Directorate City Hall.”

We agree with Matthew! We shall be lodging our objections.

If you also agree, please lodge your objections here in the Planning application comments section. These are the Important dates:

Eastgate Trees3

Bristol’s trees in crisis!

With Bristol City Council’s budget cuts, two decisions have been made regarding the management of Bristol’s treescape that make no economic sense, and threaten the reputation of the City as a Green and pleasant place to live and locate a business.

With Bristol City Council’s budget cuts, two decisions have been made regarding the management of Bristol’s treescape that make no economic sense, and threaten the reputation of the City as a Green and pleasant place to live and locate a business.

Decision 1: Slashing of street tree management budget

  • The budget for managing street trees has been cut by nearly 78% from £240,000 to £53,000.
  • As a result there will be no pollarding of street trees or removal of epicormic growth around the tree.
  • Emergency cover outside normal working hours is no longer being provided through the tree management contract, despite having no cost benefit.
  • Tree management will be limited to felling to address safety risks, despite greater initial costs and the long term consequent loss of tree sites – felling costs the same as 16 years of maintenance.  As a result, Bristol’s street tree population will rapidly fall into decline as they are steadily removed, never to be replaced.

Decision 2: No planting of street trees, either replacement or new, even when cost neutral

  • Bristol City Council has operated a number of innovative schemes allowing residents or community groups to sponsor replacement or new street trees. Despite fully funding the planting, and maintenance for two years, such planting will no longer be permitted.
  • At the moment, when a tree is replaced in an existing tree pit it costs £295. This covers regular watering until the tree is established and two years maintenance. If the trees dies whilst establishing itself, it is replaced at no extra cost.
  • If the Council can be persuaded to change its mind about not planting new trees, then this cost could to increase to the £765 that developers are required to pay – the overall costs of planting a tree and maintaining it during its lifetime. Planting a tree at a brand new site could add around £2,000-£2,500 if a special tree pit needs to be installed.
  • Currently there is huge support from the community for replacing lost trees. Around £200,000 of developers’ money is set aside for this purpose, Metrobus is committed to planting 200-300 trees as part of their planning condition, and Bristol University has donated funds to plant 60-100 public street trees.
  • It makes little sense, in times of budget constraints, to renounce external funding sources that fully cover planting and maintenance costs.

These decisions are a false economy for Bristol City Council

  • With no pollarding of street trees, increased tree growth will lead to more subsidence claims against the Council, and create more highway damage, pavement trip hazards, and infrastructure damage.
  • New tree growth from previous pollarding points will become unstable, increasing the probability of personal injury and property damage claims against the Council.
  • Just a couple of additional subsidence or injury claims could negate the Council’s entire “cost saving”.
  • This short-term decision makes no sense – if a tree can be maintained for some 16 years – the one-off cost of felling it, then surely it makes better economic sense to spread this inevitable cost and maintain the tree rather than fell it as a short-term ‘solution’ – a ‘solution’ which loads all the costs up front and will lead to greatly increased and unavoidable expenditure in not very many years time?

These decisions will threaten Bristol’s reputation as a Green City

These decisions were taken with no consultation with stakeholders

There has been no consultation regarding these decisions with other Departments within Bristol City Council, who will have to deal with the foreseeable consequences, with insurers, who will face additional damage claims, Avon and Somerset Police, who will have to address public order consequences of mass felling, or Bristol Tree Forum, with its wide-reaching understanding of tree issues.

What you can do

  • Contact your Councillor and email the Mayor and demand that these decisions be overturned.
  • Contact us here at Bristol Tree Forum to register your support and offer to help defend Bristol’s public tree spaces.
  • Spread the word and forward this blog to others interested in saving trees.