BTF response: OBJECT

We note that the tree report by All Tree Services Ltd is dated 11th December 2015 and so is 5 years out of date. In the meantime, the trees on the site will have grown and changed. An updated report should be provided before this application should be allowed proceed.

We estimate that the additional tree growth is likely to be, on average, an additional 4.61 cm to each tree’s stem diameter over the last five years (see https://bristoltreeforum.files.wordpress.com/2019/07/vaz-monteiro-et-al-2017-urban-tree-growth-rates.pdf).

We calculate that the 8 trees identified for removal have a CAVAT value of £249,375 and a tree canopy cover (TCC) of 257 sq metres.

According to Biodiversity Metric 2, these eight trees provide 0.2201 Biodiversity Units which is equivalent to 1,368 sq metres of new replacement TCC which will be needed to replace just what will be lost even without any Net Gain added.

Failure to replace and enhance lost green infrastructure is contrary to the National Planning Policy Framework and to BCS9 which states:

The integrity and connectivity of the strategic green infrastructure network will be maintained, protected and enhanced. Opportunities to extend the coverage and connectivity of the existing strategic green infrastructure network should be taken.

Individual green assets should be retained wherever possible and integrated into new development. Loss of green infrastructure will only be acceptable where it is allowed for as part of an adopted Development Plan Document or is necessary, on balance, to achieve the policy aims of the Core Strategy. Appropriate mitigation of the lost green infrastructure assets will be required.

Development should incorporate new and/or enhanced green infrastructure of an appropriate type, standard and size. Where on-site provision of green infrastructure is not possible, contributions will be sought to make appropriate provision for green infrastructure off site.

See also Policy DM15: Green Infrastructure Provision:

The provision of additional and/or improved management of existing trees will be expected as part of the landscape treatment of new development.  

We also note that the Bristol Tree Replacement Standard (BTRS) (see Policy DM17: Development Involving Existing Green Infrastructure at page 36) has not been applied. It should have been.

Under BTRS 18 replacement trees at a cost of £765.21 each will need to be provided if all the trees identified for removal are felled. If the trees are not replaced on site, then the applicant should be obliged to make a S106 payment of £13,773.78.

Our detailed analysis and calculations may be viewed here - https://bristoltreeforum.files.wordpress.com/2021/01/btf-analysis-20_05549_h-tree_report-1.xlsx.

One of our objections is the usual one about trees being lost to development. Bristol has a policy that development should retain existing trees, but sadly this happens infrequently. But I would take issue with the suggestion that whilst BTRS probably suggests that 18 trees should be planted on site or elsewhere as mitigation for the tree loss to facilitate this development, this can be partly negotiated away as some of the trees are "only hazel coppice". A tree is a tree and all trees, coppiced or otherwise make a contribution to the environment and local amenity. This is a Conservation Area and its character should be either retained or maintained, and not sawn down because it does not matter. I would ask the AO to ensure that BTRS is fully implemented - otherwise why have it? Bristol is envied and copied because of the BTRS and it should be respected.