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What Bristol’s biodiversity duty report doesn’t tell you

By the end of March this year, every council in England had to publish a report on what it is doing for biodiversity. Councils that are also local planning authorities — Bristol among them — must go further, and give details of the biodiversity net gain resulting, or expected to result, from the biodiversity gain plans they have approved.

This is done through the submission of a Biodiversity Gain Plan (BGP).

Some time earlier this year, Bristol City Council published its Biodiversity Duty Report (the Report) covering the period from January 2020 to December 2025. It is a handsome document, and much of it is genuinely positive: it lists 43,523 trees planted, canopy cover up to 18.2%, and pesticide use down 42%. 

On the question of BNG, though, it publishes only a single table which can’t answer the question a local resident might ask: Is new development in Bristol leaving our local nature better off or worse off?

What BNG is meant to do

Since February 2024 most new developments in England have had to deliver a 10% increase in biodiversity. Developers measure what’s on a site before they build — using a government metric calculation which converts various habitat types into ‘biodiversity units’ —  and then show how they’ll deliver at least 10% more biodiversity than was there before they started.

They can do this in three ways: improve habitat on the site itself; pay for habitat to be created somewhere else; or — as a last resort — buy statutory credits from the Government. Before building can start, the Council must approve the developer’s gain plan showing how the minimum 10% BNG will be achieved.

Each gain plan is a precise record (backed by a metric calculation) of what a development will achieve. Bristol has approved a number of these so far but the Report tells you almost nothing about what’s in them.

What Bristol actually published

Here’s everything the Council’s published about its approved gain plans, as listed in the Report:

Table from Bristol City Council's Biodiversity Duty Report summarising its seven approved biodiversity gain plans. On-site only: 3 plans, 2.56 units post-intervention, average net gain 275 per cent. Off-site only: 1 plan, 2.09 units. Combination of on-site and off-site: 3 plans, 3.56 units. Credits: none. No baseline figure is given for any row.

Look at the column headed ‘No. of Units post-intervention’. These are the biodiversity units expected after a development is completed. There’s no column for the value of the habitats that were there before (called the baseline). Without a baseline, we can’t know what the net gain percentage is. In the row labelled ‘On-site BNG only’ there’s a reported 275% average % net gain but the other rows are left blank, so it appears not to be an average across the seven plans reported. Three small schemes with very little habitat to begin with can easily produce a number like this: if a site starts with almost nothing, almost any new habitat can produce a large percentage increase. Published on its own, without the baseline values that would put it in proportion, it reads as a triumph but is meaningless because it lacks essential information.

What the gain plans we’ve examined say

Bristol Tree Forum has been collecting biodiversity gain plans from councils across England — 301 of them so far, from 34 authorities. We’ve found 18 for Bristol, 16 of which record a figure for the change in area habitat units on the development site. Twelve of the 16 lose habitat on site. Added together, the 18 Bristol plans show a net loss of 10.9 area habitat units within the red lines of the sites themselves. The four that gain contribute 0.24 units between them. One scheme, at Broomhill Road, records the loss of every unit on the site — 100%.

To be fair to the Council, most of those plans were approved during 2026 and so fall outside the period the Biodiversity Duty Report covers. However, six of them are dated on or before 31 December 2025 and belong squarely inside it; all of these six lose habitat on site, by 4.68 units between them.

Now, an on-site loss is not by itself a breach of anything. That’s exactly what the off-site habitat unit purchase option is for: where a site cannot accommodate the lost habitat on site, the developer is allowed to buy habitat units elsewhere to meet the 10% plus obligation. Nine of Bristol’s 18 plans deliver through a combination of on-site and off-site compensation, and four go entirely off-site. So, on paper, the obligation is met.

But a resident reading the Council’s report would have no idea that any of this was happening. The published table doesn’t state what the baseline habitat was or distinguish between gains and losses. It doesn’t say where the off-site habitat is. And it doesn’t name a single application, so there is no way to look one up.

Where does Bristol’s biodiversity go?

The report does contain one sentence that deserves more attention than it’s had. There’s no registered biodiversity gain site anywhere within the Bristol boundary. The Council’s own candidate sites ‘remain unregistered while a viable solution to procuring a legal agreement is worked towards’, and are still at scoping stage. As far as we’re aware, no Biodiversity Gain Site has yet been registered for the city.

That means every off-site unit bought to offset a Bristol development creates habitat outside the city. Thirteen of our 18 plans use off-site delivery in whole or in part. The habitat lost is in Bristol; the habitat created to compensate for it is not. So far, that compensation amounts to 14.60 units allocated to sites outside the city — 14.55 area units, 0.01 hedgerow units and 0.04 watercourse units. To see them, open https://bgs.bristoltrees.space/bgs-bodies, select LPA Allocation Maps and click on City of Bristol LPA on the map.

Other councils can manage it

Publishing a schedule of all the approved BGP approvals is not difficult. Other authorities are already doing it. For example, Cotswold District Council has published an appendix listing all 24 of its approved gain plans — application reference, date, delivery route, and the units and percentage change for habitats, watercourses and hedgerows on each one. Bolton publishes the same for its four, including the name of the habitat bank each one bought into. 

County Durham has not published a schedule of all its approved applications, but it has published the full Government reporting tables, which show, without flinching, that on-site habitat units across its 16 approved plans fell by an average of 30.85%.

Durham’s report is uncomfortable reading for Durham, but it is for that reason worth something; a report that cannot embarrass its author is not really a report.

What we’d like to see

Bristol has met the letter of its duty but it could have gone further and produced a meaningful schedule that would have made sense to the ordinary reader and been used to help inform a proper debate about how the city is (or is not) benefiting from the BNG regime. On our analysis, it’s not.

Three changes would fix this, and none of them requires new data — the Council already holds all of it:

  1. Publish the baseline alongside the post-development figure, so a net change can be worked out.
  2. List the approved gain plans individually, with the application reference, so anyone can find the application and check it.
  3. Say where the off-site units are, and how many have left the city.

There’s some urgency to this. The reporting cycle is five years, by which time a new Local Plan will probably have been adopted. If we have the information now, this might be used in the development of any new Local Plan so that it provides a real benefit to Bristolians. Unless Bristol chooses to publish an update voluntarily, the next time it’s legally required to tell us anything about biodiversity net gain will be 2031 — by which point seven years of development will have been permitted, built and largely finished, on the strength of a table that serves no practical purpose.

Bristol City Council’s Biodiversity Duty Report 2020–2025 is published at bristol.gov.uk. The figures attributed to gain plans in this article are drawn from Bristol Tree Forum’s own collection of biodiversity gain plans obtained from planning registers and freedom of information requests, and are ours rather than the Council’s. We’d be glad to be corrected on any of them.

The cover image above is extracted from the Council’s Biodiversity Duty Report.

Ancient trees, missing data, and the fight over Bristol Airport’s planned expansion

So far, most of the public alarm about this expansion has centred on Felton Common, the well-loved local nature reserve on the other side of the runway, where the airport wants to plant 8.5-metre approach lights and fencing across protected grassland. Campaigners under the Save Felton Common banner have campaigned hard against that ‘land grab’, and rightly so. But the fierce fight over the Common has largely overshadowed a second, quieter yet important threat next door — the loss of irreplaceable habitat at Cook’s Farm, which has drawn far less attention. That is what our objection is chiefly concerned with.

Bristol Airport wants to grow. Its planning application (ref. 26/P/0686/OU2) seeks permission to expand from 12 million passengers a year to 15 million. To do this, the airport needs more land — including Cook’s Farm, some 24 hectares of long-established agricultural countryside where hedgerows have stood since at least the 1840s and where some trees have been growing for centuries. The airport now proposes to compulsorily purchase the site so it can carry out its plans.

However, it first needs to persuade the planners that its proposal is acceptable. We say it’s not, and we’ve lodged a detailed objection. It is a technical document, full of hectares and habitat codes, but underneath the detail is a simple story: irreplaceable habitat is at risk, the evidence supporting the plans doesn’t add up, and the law says that should matter.

Here is what our objection says, in plain terms.

The heart of it: three veteran trees

The most emotive part of the case concerns three veteran trees growing in an ancient hedgerow on the boundary of Cook’s Farm — two Ash and one Sycamore. The airport doesn’t propose to simply cut them down. Instead, it plans to translocate them: lift them with a giant tree spade and replant them on the northern edge of the development.

That might sound like a reasonable compromise, but our objections explain why it’s not in careful detail.

A veteran tree isn’t just an old tree, especially those in long-established hedgerows. It’s a whole ecosystem — cavities, rot, deadwood and fungal growth that specialist insects, fungi and other wildlife depend on and cannot find anywhere else. These features take centuries to form. You cannot manufacture them, and you cannot move them.

Worse, veteran trees are extremely unlikely to survive being moved. Their biology works against them. Over centuries they’ve spent their reserves coping with drought, storms, disease and damage, leaving little in the tank to survive the shock of relocation. Their roots are extensive but fragile, they depend on specialised underground fungal networks built up over generations, and much of their internal wood is effectively dead but structurally essential — it can’t be repaired if damaged. Successful relocation needs around two full growing seasons of careful root preparation beforehand. Crucially, the airport’s plan makes no proposal to reduce the trees’ roots at all. As our objection bluntly puts it: if the trees are translocated without root reduction, they will die.

Our conclusion is that, for the purposes of a planning decision, these three veteran trees should be treated as lost. The airport itself seems to half-accept this: it promises a ‘compensation’ package of ten new future veteran trees and the artificial ‘veteranisation’ of ten existing trees. But you can’t conjure a veteran tree on demand. Even with the right conditions, it takes two or three decades for a ‘veteranised’ tree to start resembling the real thing — and it will still lack the fungal decay that gives a true veteran its ecological value.

The evidence doesn’t add up

Beyond the trees themselves, we found that the environmental evidence supporting the application is riddled with inconsistencies. This means that the application can’t properly be decided as it stands.

The airport is required to demonstrate that it will deliver ‘Biodiversity Net Gain’ — a calculation meant to prove development leaves nature in a measurably better state (at least 10%) than it was before development. But our objection shows the numbers in the official metric calculation simply don’t match the airport’s own ecological survey. The two documents use different habitat categories, different reference codes, and don’t cross-reference each other. Some habitats that appear in the survey are missing from the metric altogether. Habitat parcels aren’t sized, and their locations aren’t shown on the map. In short, it’s impossible to reconcile the airport’s own datasets.

The tree surveys are a particular problem. Three surveys tucked into the appendices fail to meet BS5837:2012, the British Standard for trees in planning. Between them they’re missing the surveyors’ names and qualifications, survey dates, crown-spread data, branch heights and directions, life-expectancy estimates, soil assessments, and even the number of trees in some groups. One key survey dates from June 2024 and is now out of date. And when we asked for the tree schedule in a usable spreadsheet format so we could check it, our request was refused — leaving them, in their words, to analyse the data ‘as best we can’.

Even working with that inadequate evidence, their interim analysis is striking. Of roughly 1,618 individual trees on the site, some 367 — more than a fifth — are set to be removed, along with a share of the site’s hedgerows, which the airport’s own figures and the survey record in wildly different numbers (10 hedgerow parcels in one document, 71 in another).

Why this is a matter of law, not just sentiment

This is where our objection turns from ecology to policy — and it’s the part that could decide the outcome.

National planning rules are clear about irreplaceable habitats. Paragraph 193(c) of the National Planning Policy Framework says development that causes the loss or deterioration of irreplaceable habitats — and it names ancient and veteran trees specifically — ‘should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists’.

We make two arguments about this test:

  • First, it’s a two-part test that has to be met in sequence: you need both wholly exceptional reasons and a suitable compensation strategy. A compensation package — however good, and here they say it isn’t good — cannot on its own make the reasons ‘wholly exceptional’. The decision in Juden v London Borough of Tower Hamlets [2021] EWHC 1368 (Admin) backs this interpretation.
  • Second, we argue that this scheme doesn’t clear the ‘wholly exceptional’ bar at all. The Framework’s own example of exceptional reasons is nationally significant infrastructure — the kind of once-in-a-generation project decided by government. This application, we say, is simply about increasing the capacity of an existing airport. That’s not the sort of wholly exceptional circumstance the rules have in mind.

Our objection also points to local policy. North Somerset Council’s own adopted Core Strategy (Policy CS4) requires it to protect, connect and enhance important habitats, ‘particularly designated sites, ancient woodlands and veteran trees’. The same protection is included in the Council’s emerging 2041 Local Plan. Approving the loss of these veteran trees would go against the Council’s own rules.

What it comes down to

Strip away the appendices and the acronyms, and our case is straightforward. The airport wants to expand on to land that includes centuries-old, irreplaceable habitat. Its plan to ‘move’ three veteran trees is, on the evidence, a plan to kill them slowly. The paperwork meant to justify all this is inconsistent, incomplete and in places non-compliant with the relevant standards. National and local planning policy both say irreplaceable habitat like this should be protected, not traded away for extra passenger numbers.

Our central demand is modest but firm: these problems need to be resolved before the application can properly be decided. For anyone who cares about Cook’s Farm, its ancient hedgerows and the veteran trees growing in them, that’s the line worth holding.

Here is our full response to the application:

BTF Consolidated Comments – 06 May 2026

Losing our Local Green Space designations

Are councils protecting our local green spaces? Our research reveals a worrying picture.

Parks, playing fields, village greens and community orchards are vital for our wellbeing — places where children play, neighbours meet, and nature finds a foothold in our towns and cities. Yet our research suggests that many local councils are failing to use the powers available to them to protect these spaces, leaving them vulnerable to development and neglect.

How we did our research

Using Freedom of Information laws, we contacted 62 Local Planning Authorities (LPAs) across England, asking whether their current local plan includes policies protecting Local Green Space (LGS) sites, as set out in the National Planning Policy Framework (NPPF). We also asked them whether any new local plan would do so.

The LGS designation was introduced in the NPPF in 2012 to give communities the power to protect the green areas that matter most to them. It remains part of national planning policy, and councils are expected to consider it when drawing up local plans.

Of the 62 requests sent, 55 councils have responded (88%). Eight told us they don’t hold this information. That left 47 substantive responses from councils with real power over local green space protection. Eight councils have yet to respond. The full collated responses are available online.

What we found: current local plans

Of the 47 councils that gave a substantive answer, 17 — 36% — confirmed that their current local plan includes LGS policies in line with the NPPF. Twenty-three said their current plan does not, mainly because it predates the NPPF (2012). Bromsgrove, Redditch and Stoke-on-Trent all have plans dating back to 2009/2011 and so that lack LGS provisions, though Stoke’s does contain general green space protections.

A further six councils gave qualified answers. South Hams, Stoke-on-Trent, Torbay and West Devon noted that designation of specific LGS sites has largely been left to Neighbourhood Plans. Solihull had adopted both an LGS policy and seven Neighbourhood Plans had also adopted their own LGS policies. This is a permitted approach, but one that places the burden on local communities rather than the council.

What we found: future local plans

The picture for future plans is only marginally better. Of the 47 substantive respondents, only 12 — 28% — gave an unqualified yes to designating LGS in their new or emerging local plan: Cheltenham, East Devon, Tewkesbury, Cannock Chase, Cotswold, Gloucester City, Bath and North East Somerset, Cornwall, North Somerset, Stratford-on-Avon, Swindon and Wyre Forest. Cotswold confirmed its 2025–43 plan will contain new LGS sites; Bath and North East Somerset (BaNES) proposes retaining and expanding its LGS policy, subject to Cabinet approval, and Stoke-on-Trent’s emerging plan contains LGS designations, a positive step for a city whose current plan predates the 2012 NPPF.

A further nine councils said they do not intend to designate LGS at all. Birmingham will continue using strategic, criteria-based policies rather than site-specific designations. Tamworth explicitly ruled out using LGS designations, citing limited space and preferring broader open space policies. Rugby says its emerging plan ‘defers to national planning policy’, and South Gloucestershire, despite having LGS policies in its current plan, will drop them from its new one. Broader open space policies offer some protection, but not the strong protection that LGS provides.

The largest group — 23 councils — said it was too early to tell or that no decision had been made, reflecting how slowly local plan preparation moves. Bournemouth, Christchurch and Poole, for instance, won’t be scoping consultation until June 2026.

Solihull is currently working on a new Local Plan, and will be reviewing the status of Local Green Space sites and whether there will be any amendments or additions to these.

The Bristol case: a warning from the front line

Bristol offers a stark illustration of what’s at stake. While our FOI research was under way, Bristol City Council, at the request of the examining inspectors, was removing all Local Green Space designations from its emerging local plan. Its current plan had included policy GI1, designating LGS sites identified through years of community consultation involving residents, community groups and the Bristol Parks Forum (BPF), with a matrix showing how each site met the NPPF criteria.

During examination, the inspectors rejected all proposed LGS designations as ‘not considered to be justified or effective,’ so the Council removed the policy entirely. BPF objects, pointing out that 14 sites met all five NPPF criteria and a further 27 met four, yet the Inspector rejected all designations en masse without considering the individual merits of each proposed site. BPF describe this as ‘a real disservice to the people of Bristol.’

The Council argues Bristol’s green spaces will still be protected through ‘Reserved Open Spaces’ (now call ‘Protected Open Space’ (POS)) status, but both we and BPF reject this as inadequate. POS does not carry the same weight or permanence as LGS. Other cited designations, such as Site of Nature Conservation Interest (SNCI) status, will offer weakened protection in the new proposed local plan. BPF cites Brislington Meadows as an example of a site that lost out despite its status as an SNCI. BPF says:

The only robust long-term protection for our locally important green spaces against development is to give a site Local Green Space designation. For a city like Bristol to have none is unbelievable.

Notably, Bristol’s FOI response makes no mention of this removal, instead stating that under the new system introduced by the new Levelling Up and Regeneration Act 2023 (LURA), it has ‘not yet decided’ whether its new local plan will designate LGS sites.

Both we and BPF are calling for the LGS policy and the proposed designations to be reinstated until a future local plan can provide equivalent or better protection, warning that any gap between local plans will leave green spaces exposed to development with no adequate defence.

LURA: a planning system in transition

Under LURA, there’s a transition deadline: plans submitted under the old system must be published by 31 December 2026. Authorities that fail to do this must use LURA’s streamlined 30-month timetable instead ­­— roughly half the current time required.

This is, in principle, an opportunity: many councils currently without LGS policies are operating under plans that predate the NPPF, and the obligation to produce a new plan forces the issue. But the compressed timetable, reduced consultation, and a shift of generic policies to national level all create conditions in which LGS designation could be marginalised or skipped. The Bristol example, where the Inspectors rejected all proposed LGS designations en masse, demonstrates this.

The role of Neighbourhood Plans

Local Green Space designation has often been left to Neighbourhood Plans rather than local plans. Bristol, Plymouth, Torridge, Torbay, Rugby, Solihull and Newcastle-under-Lyme all have made Neighbourhood Plans designating LGS, even where their local plan does not. These designations carry real weight, but Neighbourhood Plans require significant community time and resource. Relying on them risks a two-tier system where well-resourced communities can protect their green spaces but those with fewer resources cannot.

Why these issues matter

Bristol is a symptom of a wider problem. Access to good-quality green space improves mental and physical health, supports biodiversity, helps manage flood risk, and strengthens community cohesion. In cities like Bristol — which declared an Ecological Emergency in 2019 and is involved in nature recovery initiatives — densification without adequate green space protection directly contradicts those commitments. When councils fail to use the tools available, a community may find itself powerless to save a local green space, sometimes valued for generations, once a development application arrives.

What needs to change

Councils preparing new local plans should treat LGS designation as a core part of the process, not an optional extra, and should engage residents early on which spaces matter most. The Planning Inspectorate should also assess LGS proposals on their individual merits rather than rejecting them wholesale, as happened in Bristol. Councils currently reviewing plans that predate the NPPF have a clear opportunity to put this right.

What you can do

  • Get involved in your local plan consultation and make the case for LGS designation — and if your council is proposing to remove or weaken protections, say so clearly.
  • Ask your councillors whether your local plan protects local green spaces and what they’re doing about it.
  • Explore Neighbourhood Planning, which gives communities the power to designate LGS directly and may, in some cases, come with government funding.
  • Engage with council open-space strategies and green infrastructure reviews to help build the evidence base for future designations.
  • Support your local parks forum: organisations like the Bristol Parks Forum hold councils to account and amplify community voices. If your area doesn’t have one, consider helping to start one.

The places where we walk, play, breathe and connect with each other and with nature are worth fighting for — but only if we use the planning system’s tools, hold councils to account, and make sure that our communities are genuinely heard.

Speaking up for Bristol

The last opportunity for us to comment on Bristol’s proposed local plan has now passed, so all we can now do is hope that the Inspectors change their minds and reverse their decision to revoke all proposed LGS designations.

In any event, the Council assures us that it will publish its timetable for a further new local plan, as required under the new LURCA regime, by the end of June. When it does, we must insist that it reinstates its original ambition to adopt an LGS policy and designate LGS sites.

A copy of this article is available here: Losing our Local Green Space designation – 16 June 2026

Here are Bristol Parks Forum’s representations: Bristol Parks Forum response to Bristol Local Plan EXA064: Schedule of main modifications 11 June 2026