|Address||Stoke Park Park Road Stapleton Bristol
|Proposal||Proposed development of a formal access route through Stoke Park estate from Sir Johns Lane (Bristol) to Jellicoe Avenue (South Gloucestershire) including access works at Stanfield Close, Romney Avenue and Long Wood Meadows, following historic route and former carriage ride, comprising self-binding gravel surfaced path and associated works.|
|Type||Full Planning (Regulation 3)|
|Neighbour Consultation Expiry||15-10-19|
|Standard Consultation Expiry||02-05-19|
|Decision||GRANTED subject to condition(s)|
|BCC Planning Portal||BCC Planning Portal|
|Public Comments||Supporters: 19 Objectors: 50 Unstated: 14 Total: 83|
|No. of Page Views||0|
|Comment analysis||Date of Submission|
|Nearby Trees||Within 200m|
See also application - https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=QI5DXFDNKBR00
Bristol Tree Forum comments in respect of Planning Applications 19/01213/FB | Stoke Park Road Stapleton Bristol (Bristol City Council) and P19/3047/F | Stoke Park Estate Bristol South Gloucestershire (South Gloucestershire Council)
Bristol Tree Forum objects to this application. We argue that you have wrongly applied BS 5837:2012 - Trees in relation to construction which is designed for construction sites, not for green space or parkland. You should instead use the appropriate clauses in the National Planning Policy Framework 2019 (NPPF 2019) which we refer to.
In general we support the provision of accessible paths through green spaces and parkland, providing they can be installed sensitively and do not result in damage to, or the unnecessary removal of large, well-established trees which we oppose, as we do in respect of all the trees recommended for removal in these applications.
These comments relate just to the recommendations in the Arboricultural Impact Assessment dated 1st March 2019 and submitted as part of Bristol City Council’s and South Gloucestershire Councils’ Planning Applications 19/01213/FB & P19/3047/F. All the trees surveyed are categorised in accordance with the guidance provided in the Cascade chart for tree quality assessment at Table 1 of BS 5837.
A total of 80 individual trees, 20 tree groups and four hedges were surveyed. Trees T301 to T362 and tree groups G1 to G13 grow in South Gloucestershire. The rest and all four hedges grow in Bristol. Of the 11 trees recommended for removal, only T373 & T790 grow in Bristol.
The report recommends that seven trees be removed as a direct consequence of the proposed development, however only six are identified. These are:
1. Three B‐grade Ash trees (T351, T352 & T379). The first two grow in the wooded area at the north east corner of the estate. The third stands in a field boundary hedge at 51.488210°, -2.559173°. It has three stems, a girth of 1.4 metres, is 13 metres high, and no obvious significant defects. It is classified as category B1.
2. Three C‐grade trees (T353– a Sycamore, T355 – an Ash & T373 – a Sycamore). The first two grow in the wooded area at the north east corner of the estate. T373 grows near the radio repeater station at 51.485414°, -2.561750° and is classified a category U. It is also one of the four trees listed below. This duplication needs to be resolved.
A further four trees (T356 – an Ash, T357 – an Ash, T358 – an Ash & T373 – a Sycamore) are recommended for removal not because their removal is necessary to realise the proposed development, but because ‘they are in poor condition and have less than ten years useful life expectancy’ and ‘their removal is recommended regardless of any development proposals’. These trees are considered to be category U.
Looking at the table at Schedule One, two other trees are identified for removal, though no reason is given why this should happen. These are T359 & T360. Both are Ash. The first has a heavy lean to north over a neighbouring garden, but no obvious significant defects. The second supports arboreal ivy and has a heavy lean to north over neighbouring garden, but no obvious significant defects. Both trees are classified at C1 according to the guidance provided in Table 1 of BS5837.
BS 5837 should not be applied in this case.
The Arboricultural Impact Assessment has been carried out in accordance with BS 5837. This is designed for use when considering the retention or removal of trees in the context of development and construction of housing and commercial premises etc. It is not designed to be used when assessing trees growing in a parkland setting where the only thing being constructed is an all‐weather accessible path.
BS 5837 only considers what ‘the effect that construction requirements might have on the amenity value’. ‘Amenity value’ is not defined. Whilst any of the trees surveyed may well be capable of being categorised in accordance with this standard, BS 5837 does not take each tree’s long-term value into account, nor does it give any regard to its future contribution to the ecological benefits which trees growing in Stoke Park Estate (whatever their condition short of being dangerous) may bring.
NPPF 2019 should be applied in this case. NPPF 2019 makes it clear that (paragraph 170b):
Planning policies and decisions should contribute to and enhance the natural and local environment by…recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;
At paragraph 175c it adds:
development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons…
At Annex 2 – the Glossary it defines Irreplaceable habitat as:
Habitats which would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their age, uniqueness, species diversity or rarity…
The context of this framework is further developed in GOV.UK’s Natural environment guidance. These are the sorts of criteria that should be applied at Stoke Park Estate when considering this application.
Both Planning Authorities incorporate (or plan to incorporate) the National Planning Policy Framework into their Local Plans.
These trees should not be removed.
In our view, there are no ‘wholly exceptional reasons’ why any of these trees should be removed.
At a time when Ash trees are facing an unprecedented threat due to Hymenoscyphus fraxineus (commonly known as Ash dieback), we surely need to be keeping as many healthy Ash trees in the landscape as possible? Most of trees marked for removal are Ash.
Some of these trees, with the correct management, could well grow to be the ‘Veterans’ of the park in the future or even prove to be resistant to Ash dieback. Cavities, decay, spits and scars on trees also provide essential habitat for many species. Just because a tree may be considered to be ‘low grade’ according to BS 5837, does not mean that it does not offer many of the wider environmental and biodiversity benefits which a varied and diverse population of native trees (which these are) growing in this parkland environment bring.
In our opinion, none of the trees which need not be removed to realise the plan should be removed. This means that the six trees (T356, T357, T358, T373, T359 & T360) recommended for removal only because of their condition should be retained. It is to be expected that woodland will include a mix of trees covering a range of maturity and condition.
Of the remaining five trees - T379 should be retained. Its condition and striking position justify it. There is no reason why the line of the path cannot be adjusted to pass either side of it in much the same way that the path has been adjusted to pass between hedges H3 & H4, thus:
The gaps between T379 and T378 or T380 appear quite enough to allow this, with the possible added benefit that speeding cyclists will be forced to slow down in order to navigate the ‘chicane’.
If T373 has not been misallocated and falls into the list of trees recommended for removal in the first group above, there seems to us to be absolutely no reason why it should be felled. It is growing on open ground near the radio repeater station (the red pin in the image below) and should be easy to avoid, as the track which passes to the north of it already does.
This leaves four trees growing in the north-eastern woodland (T351, T352, T353 & T355). Given the close proximity of other trees growing close to the existing path, it seems surprising that a route cannot be found which avoids ‘colliding’ with any tree at all.
These comments are also made against the background of Bristol City Council’s recently-expressed aspiration to double tree canopy cover (TCC) from 12% to 24% by 2046 and South Gloucestershire Council’s plan to increase it from 11% to 15% by 2060. In our experience (admittedly just in Bristol), there has been a historic trend of not replacing trees that are felled, or not replacing them on a like-for-like basis. This is true particularly of street trees. This has been happening piecemeal, but its impact is likely to have led to a decline in TCC. This may not be the case in South Gloucestershire, but we are aware of the growing pressures to rezone green spaces for housing and other urban infrastructure in and around the South West. The loss of 11 trees from what appears to be a well-wooded space may not seem significant, but the same might be said for most applications to remove trees in the way of planned development. It is exactly this death-by-a-thousand-cuts approach which has contributed to this historic decline, a decline which must be reversed if both counties are going to achieve their ambition to increase TCC.
If, despite all this, either LPA concludes that trees must be felled, then we endorse their replacement in accordance with the Bristol’s Local Plan policy DM17: Development Involving Existing Green Infrastructure (p. 36) (which we encourage South Gloucestershire Council to follow in this case, if at all possible), but with the following caveats:
1. The replacement species should be well-established (not whips) natives selected with a like-for-like growth habit and eventual mature size to the trees lost.
2. Replacement trees should be planted within the Stoke Lodge Estate in consultation with the park users.
3. The calculation of the number of replacements to plant should assume that all the trees being replaced are at least of quality category C as set out in BS 5837.
Bristol Tree Forum
01 May 2019.