2

Figure 1 Table 7-2 of the guidance to BNG 3.0

The problem with this approach is that no guidance is given on how to assign a given tree with a given stem diameter to these three habitat sizes. To overcome this, we have adopted an approach which uses the median stem diameter between the three categories – 20 cm and 40 cm – to decide if a given tree is Small, Medium or Large. We have used the stem diameters (called DBH in the table below) reported in the TS. The applicant appears to have adopted a different approach and to have identified two more trees (T20 & T21) which are not reported in the TS. We have included these for completeness even though the stem diameters of these trees are not reported. This table shows the difference between our two approaches:

BTF Approach BNGA Approach

Tree ID

DBH (cm)

Size Category

**

RPA (ha)

Survey Habitat Area (ha)

Size Category

T1 33 Medium 0.0041 Urban – Urban Tree (T1) 0.0041 Medium

T2 33 Medium 0.0041 Urban – Urban Tree (T2) 0.0041 Medium

T3 20 Medium 0.0041 Urban – Urban Tree (T3) 0.0041 Medium

T4 41 Large 0.0113 Urban – Urban Tree (T4) 0.0005 Small

T5 11 Small 0.0005 Urban – Urban Tree (T5) 0.0041 Medium

T6 28 Medium 0.0041 Urban – Urban Tree (T6) 0.0005 Small

T7 27 Medium 0.0041 Urban – Urban Tree (T7) 0.0041 Medium

T8 11 Small 0.0005 Urban – Urban Tree (T8) 0.0041 Medium

T9 27 Medium 0.0041 Urban – Urban Tree (T9) 0.0005 Small

T10 13 Small 0.0005 Urban – Urban Tree (T10) 0.0005 Small

T11 9 Small 0.0005 Urban – Urban Tree (T11) 0.0005 Small

T12 17 Small 0.0005 Urban – Urban Tree (T12) 0.0005 Small

T13 30 Medium 0.0041 Urban – Urban Tree (T13) 0.0005 Small

T14 25 Medium 0.0041 Urban – Urban Tree (T14) 0.0005 Small

T15 5 Small 0.0005 Urban – Urban Tree (T15) 0.0005 Small

3

BTF Approach BNGA Approach

Tree ID

DBH (cm)

Size Category

**

RPA (ha)

Survey Habitat Area (ha)

Size Category

T16 34 Medium 0.0041 Urban – Urban Tree (T16) 0.0041 Medium

T17 21 Medium 0.0041 Urban – Urban Tree (T17) 0.0015 ?

T18 13 Small 0.0005 Urban – Urban Tree (T18) 0.0015 ?

G19 30 Medium 0.0041 Urban – Urban Tree (G19) 0.0113 Large

G19 30 Medium 0.0041 Urban – Urban Tree (G19) 0.0113 Large

T20 Small 0.0005 Urban – Urban Tree (T20) 0.0005 Small

T21 Small 0.0005 Urban – Urban Tree (T21) 0.0005 Small

Total Areas 0.0642 0.0598

** MS Excel™ Formula =IF(DBH<20,"Small",IF(DBH>=40,"Large","Medium"))

Table 1 Urban Tree Habitat Area Analysis

Using our analysis, we have assigned 0.0642 hectares of baseline Urban Tree Habitat to our BNG

3.0 calculation.

Of the 20 trees identified in the TS, six will be removed. Under BTRS, ten new trees will be

required to replace the trees being removed. The applicant proposes that these be planted on

site. The six trees being removed provide 0.0172 hectares of Urban Tree habitat, which means

that 0.0470 hectares of Urban Tree habitat will be retained. We have factored this into our

calculation.

2. Urban Tree habitat creation

We have assumed that the ten trees the applicant proposes to plant on site will be Standard-

sized trees (such as those planted as street trees in the city). We have therefore used the Small

tree category in BNG 3.0 – DBH 10cm. This will generate 0.0045 hectares of new habitat after

a Time-to-Target period of 27 years.

The applicant has assumed that ‘Any new trees planted to replace removed trees will be semi-

mature, therefore, a value of 6 for ‘Habitat created in advance/ years’ was chosen within the

metric.’ The assumption seems to be that these trees will be six years old and so be planted,

as it were, with a pre-existing habitat value. We have not come across this approach before,

but logic suggests that no six-year old tree is ‘semi-mature’, let alone when the assumption in

BNG 3.0 is that an urban tree will take 27 years before it provides any meaningful ‘habitat’;

most trees are just beginning to mature after 27 years.

4

The purpose of biodiversity net gain is to create habitat from scratch in the development

location. There is no evidence that these trees will be planted before development begins. If

anything, there is likely to be a delay while infrastructure of the site is developed.

We have set the ‘Habitat created in advance/ years’ period to zero.

3. Urban Tree habitat condition assessment

The BNGA gives different condition assessments for each of the trees on the site, ranging from

Poor to Fairly Good. We are not sure what criteria have been used, but it does not comply with

the requirements of BNG 3.0 (see Appendix 2). While there are arguments that the BNG 3.0

approach is flawed, its application in this case means that the condition of all the Urban Tree

habitat can only be set as Poor. We have combined all the individual Urban Trees habitats

identified in the BNGA into a single, combined habitat as a result.

4. The Malago River

The applicant has failed to include the Malago River, which runs through the site, in its BNG

3.0 calculation. We have assigned 0.062 kilometres of Other Rivers and Streams habitat in Poor

condition (the river is culverted here) to our calculation. The habitat has low strategic

significance because it has Low potential/action not identified in any plan and no

encroachment.

On this basis, the suggested action is to restore the river. Given that there are plans to restore

the river barely 500 metres from the site, it is surprising that there are no plans to restore the

river here at the same time, given these proposals.

5. Strategic significance

We do not agree that the site has a low strategic significance – ‘Area/compensation not in local

strategy/ no local strategy.’

The site is immediately adjacent to the River Avon SNCI and the River Bank Important Open

Space. It is in the Bedminster Conservation area, on the course of the Malago River and is

subject to a Tree Canopy TPO, which covers most of the eastern half of the site.

We have set high strategic significance – ‘Within area formally identified in local strategy.’ –

for all baseline and created habitats.

We have submitted a copy of our BNG 3.0 calculation with these comments.

Bristol Tree Forum

22 April 2022

5

Appendix 1 – Biodiversity Net Gain Headline Results

6

Appendix 2 - Biodiversity Metric 3.0 Technical Supplement - 22 Urban trees

Tree Condition Assessment Criteria

Score Condition Assessment Criteria

1 More than 70% of trees are native species.

2 Tree canopy is predominantly continuous with gaps in canopy cover making up <10% of total area and no individual gap being >5 m wide.

3 More than 50% of trees are mature2 or veteran3.

4

There is little or no evidence of an adverse impact on tree health by anthropogenic activities such as vandalism or herbicide use.

There is no current regular pruning regime, so the trees retain >75% of expected canopy for their age range and height.

5 Management regime has encouraged micro habitat sites for birds, mammals and insects e.g. presence of deadwood, cavities or loose bark etc.

6 Trees are immediately adjacent to other vegetation, and tree canopies are oversailing vegetation beneath.

Condition FC Condition Assessment Score

Good Passes 5 or 6 of 6 criteria

Moderate Passes 3 or 4 of 6 criteria

Poor Passes 0, 1 or 2 of 6 criteria

7

This proposed develpement will be substantially detrimental to the character of the localarea.The height of the develoment is totally out of keeping with the area, where most otherproperties are no more than 3 stories high. Four or five stories would be quite unacceptable.Residents of neighbouring properties would be overlooked and overshadowed.Southville consists almost entirely of period housing of considerable historical character, and anynew development should have to be in keeping both in design and height.Much as I realise that car ownership and travel needs to be curtailed in the current climateemergency, there is bound to be an increase in demand for parking places with this develpoment.There is already a shortage of parking for local residents, particularly at weekends and evenings.For some existing rlocal residents a car is a lifeline. The existing residents of Southville Placewould suffer serious competition for parking in their street if the building of 46 new homes goesahead, as there is little street parking in St John's Lane or Coronation Road.This is an ill-conceived development and should not be granted permission to go ahead.

This proposed develpement will be substantially detrimental to the character of the localarea.The height of the develoment is totally out of keeping with the area, where most otherproperties are no more than 3 stories high. Four or five stories would be quite unacceptable.Residents of neighbouring properties would be overlooked and overshadowed.Southville consists almost entirely of period housing of considerable historical character, and anynew development should have to be in keeping both in design and height.Much as I realise that car ownership and travel needs to be curtailed in the current climateemergency, there is bound to be an increase in demand for parking places with this develpoment.There is already a shortage of parking for local residents, particularly at weekends and evenings.For some existing rlocal residents a car is a lifeline. The existing residents of Southville Placewould suffer serious competition for parking in their street if the building of 46 new homes goesahead, as there is little street parking in St John's Lane or Coronation Road.This is an ill-conceived development and should not be granted permission to go ahead.

Windmill Hill & Malago Community Planning Group (WHaM) response to application no21/02976/F

Though not a statutory consultee, the group felt it wanted to submit our views on the proposals asit is within the locale that our members experience daily and has previously been commentedupon by our group.

We would note that the previous time we looked at the scheme it was taller and of a much differentcharacter, since then the scheme has been reduced in height and more variation introduced to itsfaçade. The introduction of the landscaped garden is also a welcome addition where some wouldhave been tempted to place more accommodation or parking.

The group felt that there were a number of positives within the scheme:

Affordable housingThe affordable units are dotted throughout the scheme rather than isolated to one side, we felt thiswas positive as such isolation frequently means they seem somehow 'lesser' than the otheraccommodation. We were however disappointed that only 9 out of the 46 units were affordable,just under 20%.

Family accommodationThe group was pleased to see some larger units 3B4P and 3B5P but would have liked to seemore. The area needs family accommodation and the group felt that an assessment of thehousing provision in the area might have steered the scheme towards larger types ofaccommodation. There was some concern about how the living spaces in the 3 bedroomaccommodation were laid out.

LandscapingA generous portion of the scheme has been given over to soft landscaping and includes seating.The courtyard verses the more open garden to the East offers a variety of outlook, howeverbeyond private terraces, there seems little given over as play space. We were unconvinced thatgravel or paving offers the best type of surface for such activity. Perhaps some grass would havebeen a positive addition. It was noted that the nearest park with play space is 400m away at DameEmily Park. Victoria Park is over 500m and requires a main road to be crossed. In accordance withthe urban living policy document space was set aside for play.

SustainabilityThe report into energy generation and sustainability starts off looking at the longer term view of theclimate crisis we face and the government targets that have been set.It was disappointing that the on-site renewables result in only 20% CO2 reduction when in factthere is capacity for more, when the deeper problem is acknowledged in the same document.The introduction of a CHP is noted, but we appreciate that this is not an energy saving measurebut an energy efficiency measure. The introduction of such technology with such fumes andexhaust is surely not a good idea within an air quality management area.

It was noted that many aims were set in the energy and sustainability statement, but that few hadnumerical targets set against them. Quantifiable targets on the materials and waste would bewelcome. Targets on rainwater runoff attenuation in excess of the minimum required by the citycouncil would also help mark the scheme as one aware of the issues we face and not just payinglip service to policy and broadly ignoring the spirit of it.

The commitment to increased levels of planting is noted and appreciated. It is a shame that suchenthusiasm and consideration was not given to the other areas of sustainability noted in the report.

Height and massingThe group recognises that effort has been made to visually break down the mass of the buildingthrough elevational treatments, changes in materials and adjusting the roof form. This has notbeen entirely successful as the scheme still appears much taller than the neighbours and as suchappears to be an abrupt departure from the existing context. The height steps up very quickly to 4storeys from the 2 storey scheme next door, and the 5 storey building to the east of the plot risksovershadowing the courtyard to the west.

It was felt that the context elevation SJG-AFA-XX-ZZ-DR-A-1120 was a little misleading due to thewhite boxes (intended to show buildings in the background) though the one to the left distractedfrom the contrast in height of the new buildings against the existing one.

WHaM OBJECTS TO THIS APPLICATION.

No information has been given to local residents before the expiry date to comment dueto no postal service in BS3 area.(covid)As the owner of a neighbouring property I object on the grounds of size, disproportionate to thesurrounding properties. Neighbouring properties including mine will be over looked.Access via Lucky Lane is impractical. The development is not appropriate in a conservation area,particularly the sight line along Coronation Rd towards St Paul's Church.

I would firstly like to point out that due to staff having to isolate, bs3 has not receivedpost in weeks which means nobody in this area has been formally informed of this planning. I thinkthis should be taken into consideration when looking at who has given an opinion and if they weregiven the fair opportunity?I would firstly like to say I am very distressed at the thought of having yet MORE noise pollution inthis area. Since moving to this flat last year, we have put up with endless building and demolition.The area is constantly a hub of lorries, drilling and delivering 24/7. Although this can somewhat beexpected in a city, I think it is fair to allow residents a break. The thought of having even yetanother building site is worrying, and the fact it will be right up against our bedroom wall makes meworry for both me and my partners mental health.I would like to also point out that working as a conservationist, I am all to aware of the wildlife thatlives in this area. Bats live and breed in this area, specifically around the trees out the back of46/47. I am correct in thinking this must be correctly surveyed before any planning can go aheadas they are protected?I would also greatly effect breeding birds, some of which are birds of prey and various birds thatlive along the harbourside. Will the trees be protected? As a green city I see no sense in theconstant pulling down of healthy trees!Lastly, I would like to express my concern about the effect on traffic. Being on a main junction ofcoronation road I dread to think of what it will do to the traffic, and the rise in pollution in the area.I think overall this is a terrible idea for what seems to be a set of houses which are totally liveable.

Bristol is constantly under attack by people who wish to profit in the housing market, and rarelyaccommodate those who are looking for affordable housing. Please reject this planning!

I am worried about the invasion of privacy that buildings such as those proposed wouldinflict upon my residence along with others.Having such a high building close by is going to cause a much greater potential for onlookers intoour home. Our home being positioned where it is along with its structure make it a good target forbreak ins and I feel that the increased attention turns this into a bigger risk.

I also feel like it would be of great detriment to the view from our flat, we have limited view at thefront of the flat and enjoy seeing the trees out the back. These trees also provide homes forwildlife that my partner and I very much enjoy having around.

We already have to deal with the ongoing work at Asda and feel that additional work wouldbecome stressful, especially as it is of such an immediate vicinity.

Most importantly I feel that I was not given enough notice of these plans, apparently tonight is thedeadline to have input and I had not received any information formally, luckily I was told a fewhours ago and so have looked at the proposals but feel it would have been proper to have beengiven more notice.

The Panel understands that the culvert crossing the site prevented the new buildingaddressing St Johns Road in a more sympathetic manner.

The North elevation and the cornice line which responded to the existing terrace was acceptablebut the mansard roof to the top storey was not set back far enough, making this element toodominant.

The East elevation on St Johns Road would be 5 storeys high which was too overbearing for thissecondary road.

Despite the assertions of the developers our comments on the initial pre-application andconsultation could be best described as lukewarm at best.

Sadly now that the full application has been made we cannot support the development as itcurrently stands as:

It is too high in relation to adjoining buildings.

Some attempt has been made to ensure the frontage 'fits in' with the rest of the housing but themansard roof does nothing to enhance the visual appeal fo the building.

From the side and rear the property presents an ugly 'blocky' structure of the type which seem socommon in recent developments but are ugly to those around them.

This development does not enhance or improve the local conservation area

I am already registered as number 1 Lucky Lane so this development must not use thataddress.