Members of the Bristol Tree Forum (BTF) recently met with senior Planning Officers and the two Arboricultural Officers working in the Department. We wanted to raise a number of planning issues that have been concerning us.
The Bristol Tree Replacement Standard (known as BTRS – you can find it at page 21 of the Council’s Planning Obligations Supplementary Planning Document) is a flagship policy copied by other planning authorities. Bristol should be proud of it. We are because it goes a long way towards making sure that trees and tree canopy lost to development is replaced at the expense of the developers.
This is how the BTRS formula is applied (the diameters shown are in centimetres):
However, in the years since its inception about ten years ago it has become apparent to us that the policy could be improved if some changes to the way it is applied were made to it. Two things that have particularly concerned us are:
Firstly, it had become apparent that developers and householders developing land in Conservation Areas were avoiding their obligation to mitigate tree loss by submitting two separate planning applications – the first for the trees to be felled (usually for some spurious reason), then, months later, a substantive application to develop the now tree-free land.
Outside Conservation Area, where there is no protection for trees (unless they have a TPO) at all, the trees were simply being felled, sometimes in large numbers, some time before an application to develop the land was submitted.
In either situation, if the development was permitted, the trees were lost, never to be replaced, because the loss was not considered to be “in association with” the development of the land.
Secondly, if developers or householders were developing land and the BTRS was being applied, we noticed that in some cases, hedging was being approved as a replacement for the lost tree canopy. Whilst grand hedging might indeed be appropriate as part of the planning proposal – say as screening or as a pollution mitigation measure – we do not believe that it can ever be used as an adequate substitute for lost tree canopy.
In particular, we noticed that this option was being proposed by those developers who had filled nearly all of the site so that there was little, or no room left for replacement tree planting on site. In our view this was being done to avoid having to pay the Council (us really) for replacement trees to be planted nearby.
We are pleased to report that, after several meetings with Officers to discuss our concerns, the following has finally been agreed:
- Where there is evidence of prior felling, BTRS will be applied retrospectively to include all trees felled within the year before the planning application. In this way any trees felled before the development will be taken into account when considering the application of BTRS.
- Other than in exceptional circumstances, hedges will no longer be acceptable as mitigation for tree canopy loss when applying BTRS.
- If council officers think it is necessary, these new protocols will be written into the Council’s Planning Practice Note so that there is no possibility of any future misunderstandings by either developers or planning officers how BTRS is the be applied.
BTF has more ideas which we believe will strengthen the application of BTRS (for instance, why should trees under 15 cm not be replaced?; should BTRS be applied in non-development tree felling applications?) . We will continue to advocate for these and other possible changes.
We accept that there is always going to be development, but we must try to ensure that the city’s tree cover is, at the very least, protected and maintained in keeping with SDG 15 – Life on Land of the One City Plan Sustainable Development Goals which commit to doubling tree canopy cover by 2046.