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The planning statement – June 2020

Trees

7.39. Policy DM17 of the Development Management Policies refers to the integration of

existing trees into development. It states that where tree loss is accepted, replacement

provision in line with the Bristol Tree Replacement Standard (BTRS) should be provided.

7.40. In order to facilitate the proposed development, 5 individual tress and 2 tree

groups are proposed to be removed. The accompanying Arboricultural Impact

Assessment confirms that these trees are of moderate (Category C trees), thus the

principle of their removal is acceptable subject to suitable tree replacement planting.

In line with the BTRS, 45 trees are required to be planted within the site to compensate

the loss of these trees. The proposed landscaping includes the planting of 28 new trees

within the site. These are planted within areas where they offer high amenity value

such as communal gardens, between parking spaces and along the enhanced PRoW.

Figure 6 – Proposed landscaping for development

7.41. Onsite planting provision leaves a BTRS shortfall of 17 trees, which the applicant

proposes to compensate via a financial contribution that allows suitable tree planting in

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the area. The proposals therefore satisfy the requirements of the policies BCS9 of the

Core Strategy and DM17 of the Development Management Policies.

The Arboricultural Impact Assessment [AIS] has now been published, but we are still

unable to verify this information at no tree numbers or stem diameters for any of the

group trees have been given, so we have to rely instead on Table 3 Bristol Tree

Replacement Standard calculations instead.

Our submission

1. The planning background

The National Planning Policy Framework

The National Planning Policy Framework (NPPF) seeks to ensure that new development is

sustainable. It stresses the importance of Green Infrastructure as one of three overarching,

interdependent objectives – economic, social, and environmental. This means that the

presumption in favour of sustainable environmental development is just as important as any in

respect of economic or social development objectives.

Trees are an integral part of this because of the importance of trees in relation to the

management of air, soil and water quality along with other associated ecosystem services,

climate change adaptions and beneficial health effects. The NPPF also seeks to achieve the

protection and enhancement of landscapes and achieve Net Gain in biodiversity.

The Natural England Joint Publication JP029 - Biodiversity Metric 2.0 (BDM2) provides a way of

measuring and accounting for biodiversity losses and gains resulting from development or land

management change. It defines Net Gain as an:

“approach to development that aims to leave the natural environment in a measurably

better state than beforehand. This means protecting existing habitats and ensuring that

lost or degraded environmental features are compensated for by restoring or creating

environmental features that are of greater value to wildlife and people. It does not

change the fact that losses should be avoided where possible, a key part of adhering to

a core environmental planning principle called the mitigation hierarchy.”

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The Mitigation Hierarchy

Avoid - Where possible habitat damage should be avoided.

Minimise - Where possible habitat damage and loss should be minimised.

Remediate - Where possible any damage or lost habitat should be restored.

Compensate - As a last resort, damaged or lost habitat should be compensated for.

This is a cascading decision process - only if the preceding choice is unavailable is the next

considered.

Local Planning Authorities (LPA) in the UK have a statutory duty to consider both the protection

and planting of trees when considering planning applications. The potential impact of

development on all trees is therefore a material consideration. In particular, BCS9 of the Core

Strategy states that "Individual green assets should be retained wherever possible and

integrated into new development".

We have summarised Bristol’s planning policies as they relate to trees here - Planning

obligations in relation to trees in Bristol.

All our calculations, summarised below, can be examined in this linked spreadsheet.

2. The CAVAT calculation

Using CAVAT we have calculated that those identified trees which have a measured stem

Diameter (DBH) are worth £461,979. As the AIS fails to give the upper life expectancy ranges1

of the majority of trees, we have assumed that all those trees given a 10+ years life expectancy

will survive between 40 and 80 years. This attracts a 5% discount on the base valuation. We

have applied a CTI factor for Bristol of 1502. All the other factors are set to their default values.

1 CAVAT uses six age ranges to set the discount factor. 2 Bristol has a population of 459,300 and a land area (as opposed to the Administrative area which covers large parts of the River Avon and coastal margins) of 10,970 hectares. Using this gives a population per hectare of 41.9 (459,300/10,970) and so a CTI Index value of 150.

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3. The BTRS calculation

29 trees are identified for removal. Of these, one tree group of two trees is categorised as

Category ‘U’ trees under BS5837:2012 Trees in relation to design demolition and construction,

and so has not been taken into account for the purpose of the Bristol Tree Replacement

Standard (BTRS) calculation. One further tree is also excluded because its stem diameter is

under 15 cm.

We advocate that all trees identified for removal should be replaced no matter what their size

or categorisation.

Notwithstanding this and based on the current guidance, we have calculated the BTRS value at

45 trees as per the AIS calculation.

4. Net Gain calculation

No Net Gain calculation has been undertaken using BDM2 in support of this application.

In the absence of a published AIS, which will show individual tree measurements, we have

instead measured the woodland tree canopy in the north eastern corner of the site at 1,713

square metres (0.1713 hectares). In our view this area fairly represents the extend of tree cover

on the site as this is where most of the trees proposed for removal are growing. This is the only

basis upon which we are able evaluate these proposals.

Our BDM2 calculation3 is just this measured woodland area, but a full calculation needs to be

undertaken in respect of the whole of the site. This will inform any future decision about

achieving Net Gain if this development is to be allowed to proceed.

On the basis that the combined tree canopy cover is 0.1713 hectares, we have set the A-1 Site

Habitat Baseline Habitat Type to Urban – Urban Woodland in the calculation. This assumes,

amongst other things, that any replacement trees will reach maturity in 27 years.

3 We are happy to make the calculation available on request.

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This gives Base Habitat Units of 1.658 and a Base Replacement value of 0.45 hectares. If we

add an arbitrary Net Gain value of 10%4, then the Base Habitat Units increase to 1.824 and the

Base Replacement value to 0.49 hectares. Assuming that a 27-year-old tree has a canopy of

.00403 hectares, then 122 replacement trees will be needed to replace what has been lost in

order to achieve a Net Gain of base plus 10%.

5. Loss of the ecosystem services of trees

We invite you to consider the decades-long damage that felling just one tree will cause by

inputting the DBH of any tree identified for removal into our Tree CO2 Calculator.

As you will see, when an equivalent tree is replaced on a one-for-one basis, the lost CO2e is

never recovered. Even when the largest tree (one with a DBH of 80 cm or greater) is replaced

with eight trees in accordance with BTRS, it will still take some 40 years to recover the lost

CO2e. And this is just one of the eco-services that trees provide us!

6. Lost Biodiversity

We note the statement made in the summary to the Biodiversity Statement of last March:

Due to the loss of semi-natural habitats including woodland, scrub and ephemeral/ short

perennial vegetation to a developed landscape, the overall reduction in habitat

biodiversity value within the Site is inevitable. To help compensate for this, the Proposed

Development has incorporated a variety of biodiversity enhancements into the scheme,

including the incorporation of native species and species-rich habitats where appropriate

and removal of plant INNS on Site.

Whilst we welcome these assurances, we note that they will only help compensate for the

inevitable reduction in the overall biodiversity value within the Site and remain concerned

that no baseline or post-development biodiversity survey has been undertaken (such as the one

we have done for the trees using BDM2 above) to verify if these aspirations are indeed offering

true Net Gain.

4 The choice is arbitrary chosen only for the sake of illustration. We are not advocating a Net Gain of 10%, though the concept of Net Gain implies an improvement on the base values.

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Bristol Tree Forum

28 July 2020

07 August 2020

Comments from Lockleaze councillors Gill Kirk and Estella Tincknell in support of this application:

As councillors we attended the local consultation events. We felt that the community were given good opportunities to engage, see the plans, talk to architects and council officers and give comments and feedback. We appreciate the liason that also took place with the Lockleaze Residents’ Planning Group. We have not received direct correspondence from residents in opposition to this development. We know from previous community consultation and the Our Lockleaze Community Plan 2019-24, that many residents are supportive of more affordable housing being built in the area. This is a brownfield site close to bus routes and local amenities so we believe it to be suitable for housing development.We support the designs and the communal outdoor space, which we hope will encourage a neighbourly and cohesive development.

We were aware of some concerns initially expressed by a few residents at the consultation, regarding the somewhat stark appearance of the buildings and materials facing onto Muller Rd, but note that designs and materials have been amended in response to this feedback.We note that access to the site has been designed in co-ordination with the Muller Rd transport improvements. We expect these improvements, when implemented, will reduce congestion on Muller Rd and improve bus routes and walking and cycling options to support new housing development in Lockleaze.

As councillors we must raise a key infrastructure concern:

1. Capacity of the local GP surgery. Horfield Health Centre. With the increase in resident numbers in the new housing, the council and developers must work with the CCG to ensure this surgery has sufficient new clinical and admin staff, and space on its premises to accommodate these new staff, and extra patients. Bearing in mind Horfield surgery has recently absorbed high numbers of patients from two closed family surgeries nearby, these negotiations must take place urgently so that the surgery can plan and prepare for the expansion that is required.

We enclose and endorse the points made by the Lockleaze Residents’ Planning Group relating to all new developments in Lockleaze and particularly wish to highlight the need for a local lettings policy to ensure local people in housing need benefit from the new homes.

The Lockleaze Residents Planning group have made the following comments to the Local Plan response with regard to all developments in Lockleaze: Broadband should be as standard on all developments with a choice of providers (FTTP) should be the standard to future-proof connection needs Supplementary guidance to restrict conversion of family homes to HMOs, new developments should restrict the number of properties that can be bought to avoid buy-to-let Affordable Housing should be 40% minimum (aim for 50%) with 20% council, social or ethical rent and a range of tenures A local lettings policy should be applied on all new sites in Lockleaze Residents should be encouraged to downsize as part of new developments and a local lettings policy applied to the re-let of 3 and 4 bed family homes A new Lockleaze Railway station to support sustainable travel Resurfacing of Romney Avenue, Constable Road and Bonnington Walk so that as traffic increases the noise levels are not impacting on residents quality of life, cycling infrastructure should be considered as part of this New developments to include electric car charging, car club spaces and support for electric bike scheme A commitment to accessible home standards Higher density should be achieved through infill and as appropriate in areas such as around Gainsborough Square, Developers and planning officers should be mindful to maintain views from Gainsborough Square (and Stoke Park beyond) across to Southmead hospital and keep a stepped approach to housing height so as not to obscure these vistas across the city Lockleaze is blessed with lots of green space and developments should seek to maintain cul-de-sacs and green space, and increase trees lining the streets Developers should create hoardings with information about the development when they own the sites and are actively progressing them keep local people up to date with what is happening.

Gill KirkCouncillor for Lockleaze (Labour)

I have reviewed the application documents and our focus remains ensuring that thedevelopment allows the improvement work to upgrade PROW BCC/143 which runs along thesouthern edge of the development site to provide a 2m tarmac surface throughout, as per myresponse to the pre-application for this development.

As also confirmed at the pre-application stage, and given that the development documentsemphasise links from the central shared space open area to and enhancement of BCC/143, wewould hope to receive additional S106 funding from this application to supplement the fundingalready allocated from the adjacent Lidl development to fund the PROW improvement works. Inote that this does not appear to be included in the Planning Obligations documents included withthe application. An alternative would be that the developers include this PROW improvement workas part of their site construction works, although this does not appear to be included in their plans.

We would also look for coordination of the PROW surface improvement works with the boundarytreatments and landscaping works along the PROW identified in the development plans.

bristoltreeforum.org

The planning statement – June 2020

Trees

7.39. Policy DM17 of the Development Management Policies refers to the integration of

existing trees into development. It states that where tree loss is accepted, replacement

provision in line with the Bristol Tree Replacement Standard (BTRS) should be provided.

7.40. In order to facilitate the proposed development, 5 individual tress and 2 tree

groups are proposed to be removed. The accompanying Arboricultural Impact

Assessment confirms that these trees are of moderate (Category C trees), thus the

principle of their removal is acceptable subject to suitable tree replacement planting.

In line with the BTRS, 45 trees are required to be planted within the site to compensate

the loss of these trees. The proposed landscaping includes the planting of 28 new trees

within the site. These are planted within areas where they offer high amenity value

such as communal gardens, between parking spaces and along the enhanced PRoW.

Figure 6 – Proposed landscaping for development

7.41. Onsite planting provision leaves a BTRS shortfall of 17 trees, which the applicant

proposes to compensate via a financial contribution that allows suitable tree planting in

bristoltreeforum.org

the area. The proposals therefore satisfy the requirements of the policies BCS9 of the

Core Strategy and DM17 of the Development Management Policies.

As, to date, no Arboricultural Impact Assessment [AIS] has been published, so we are

unable to verify this information.

Our submission

1. The planning background

The National Planning Policy Framework

The National Planning Policy Framework (NPPF) seeks to ensure that new development is

sustainable. It stresses the importance of Green Infrastructure as one of three overarching,

interdependent objectives – economic, social, and environmental. This means that the

presumption in favour of sustainable environmental development is just as important as any in

respect of economic or social development objectives.

Trees are an integral part of this because of the importance of trees in relation to the

management of air, soil and water quality along with other associated ecosystem services,

climate change adaptions and beneficial health effects. The NPPF also seeks to achieve the

protection and enhancement of landscapes and achieve Net Gain in biodiversity.

The Natural England Joint Publication JP029 - Biodiversity Metric 2.0 (BDM2) provides a way of

measuring and accounting for biodiversity losses and gains resulting from development or land

management change. It defines Net Gain as an:

“approach to development that aims to leave the natural environment in a measurably

better state than beforehand. This means protecting existing habitats and ensuring that

lost or degraded environmental features are compensated for by restoring or creating

environmental features that are of greater value to wildlife and people. It does not

change the fact that losses should be avoided where possible, a key part of adhering to

a core environmental planning principle called the mitigation hierarchy.”

bristoltreeforum.org

The Mitigation Hierarchy

Avoid - Where possible habitat damage should be avoided.

Minimise - Where possible habitat damage and loss should be minimised.

Remediate - Where possible any damage or lost habitat should be restored.

Compensate - As a last resort, damaged or lost habitat should be compensated for.

This is a cascading decision process - only if the preceding choice is unavailable is the next

considered.

Local Planning Authorities (LPA) in the UK have a statutory duty to consider both the protection

and planting of trees when considering planning applications. The potential impact of

development on all trees is therefore a material consideration. In particular, BCS9 of the Core

Strategy states that "Individual green assets should be retained wherever possible and

integrated into new development".

We have summarised Bristol’s planning policies as they relate to trees here - Planning

obligations in relation to trees in Bristol.

2. Net Gain calculation

No Net Gain calculation has been undertaken using BDM2 in support of this application.

In the absence of a published AIS, which will show individual tree measurements, we have

instead measured the woodland tree canopy in the north eastern corner of the site at 1,713

square metres (0.1713 hectares). In our view this area fairly represents the extend of tree cover

on the site as this is where most of the trees proposed for removal are growing. This is the only

basis upon which we are able evaluate these proposals.

Our BDM2 calculation1 is just this measured woodland area, but a full calculation needs to be

undertaken in respect of the whole of the site. This will inform any future decision about

achieving Net Gain if this development is to be allowed to proceed.

1 We are happy to make the calculation available on request.

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On the basis that the combined tree canopy cover is 0.1713 hectares, we have set the A-1 Site

Habitat Baseline Habitat Type to Urban – Urban Woodland in the calculation. This assumes,

amongst other things, that any replacement trees will reach maturity in 27 years.

This gives Base Habitat Units of 1.658 and a Base Replacement value of 0.45 hectares. If we

add an arbitrary Net Gain value of 10%2, then the Base Habitat Units increase to 1.824 and the

Base Replacement value to 0.49 hectares. Assuming that a 27-year-old tree has a canopy of

.00403 hectares, then 122 replacement trees will be needed to replace what has been lost in

order to achieve a Net Gain of base plus 10%.

3. Loss of the ecosystem services of trees

We invite you to consider the decades-long damage that felling just one tree will cause by

inputting the DBH of any tree identified for removal into our Tree CO2 Calculator.

As you will see, when an equivalent tree is replaced on a one-for-one basis, the lost CO2e is

never recovered. Even when the largest tree (one with a DBH of 80 cm or greater) is replaced

with eight trees in accordance with BTRS, it will still take some 40 years to recover the lost

CO2e. And this is just one of the eco-services that trees provide us!

4. Lost Biodiversity

We note the statement made in the summary to the Biodiversity Statement of last March:

Due to the loss of semi-natural habitats including woodland, scrub and ephemeral/ short

perennial vegetation to a developed landscape, the overall reduction in habitat

biodiversity value within the Site is inevitable. To help compensate for this, the Proposed

Development has incorporated a variety of biodiversity enhancements into the scheme,

including the incorporation of native species and species-rich habitats where appropriate

and removal of plant INNS on Site.

Whilst we welcome these assurances, we note that they will only help compensate for the

inevitable reduction in the overall biodiversity value within the Site and remain concerned

2 The choice is arbitrary chosen only for the sake of illustration. We are not advocating a Net Gain of 10%, though the concept of Net Gain implies an improvement on the base values.

bristoltreeforum.org

that no baseline or post-development biodiversity survey has been undertaken (such as the one

we have done for the trees using BDM2 above) to verify if these aspirations are indeed offering

true Net Gain.

Bristol Tree Forum

28 July 2020

We have submitted our comments on this application which can be found here:

https://bristoltreeforum.files.wordpress.com/2020/07/former-brunel-ford-muller-road-planning-statement.pdf

I am strongly objecting these plans of development as I have serious concerns in which the following questions will need to be answered with honesty and professionalism before any support can be put forward from us:-

- How far will the development be built from my property/boundaries e.g. yards

- How long will the work continue as my Husband and I work shift-hours being key workers and have concerns of disruption at times during the day/night

- What types of properties will be built on this development? I am concerned with lack of privacy on my property if flats are being proposed

- How will you rectify any structural damages to my property with any movements of iron, timber and bricks due to hard drilling / construction work

- The land that is being built on is private land; have and how have you gained the correct approval to build on this land which is situated in adjacent to my rear garden

- How far will the development be built from my property/boundaries as I have a Garage situated next door to the former Ford Brunel Dealership e.g. yards

I look forward to your response

I am strongly objecting these plans of development as I have serious concerns in whichthe following questions will need to be answered with honesty and professionalism before anysupport can be put forward from us:-

- How far will the development be built from my property/boundaries e.g. yards

- How long will the work continue as my wife and I work shift-hours being key workers and haveconcerns of disruption at times during the day/night

- What types of properties will be built on this development? I am concerned with lack of privacyon my property if flats are being proposed

- How will you rectify any structural damages to my property with any movements of iron, timberand bricks due to hard drilling / construction work

- The land that is being built on is private land; have and how have you gained the correctapproval to build on this land which is situated in adjacent to my rear garden

I look forward to your response

I am strongly objecting these plans of development as I have serious concerns in whichthe following questions will need to be answered with honesty and professionalism before anysupport can be put forward from us:-

- How far will the development be built from my property/boundaries e.g. yards

- How long will the work continue as my Husband and I work shift-hours being key workers andhave concerns of disruption at times during the day/night

- What types of properties will be built on this development? I am concerned with lack of privacyon my property if flats are being proposed

- How will you rectify any structural damages to my property with any movements of iron, timberand bricks due to hard drilling / construction work

- The land that is being built on is private land; have and how have you gained the correctapproval to build on this land which is situated in adjacent to my rear garden

- How far will the development be built from my property/boundaries as I have a Garage situatednext door to the former Ford Brunel Dealership e.g. yards

I look forward to your response