Comments on Draft LEMP – 09 April 2024

2

baseline habitat units of 27.0233 HUs to 24.0383 HUs overall. This ‘adjustment’, together

with the other changes, has had the effect of increasing the total net percentage area unit

change from 2.93% to 13.05%, even though the value of these habitats has been reduced.

This needs to be explained.

4. The offsite habitats, at the least, need to be registered.6

5. No future funding budget is provided. The funding for the LEMP/HMMP needs to be ring-

fenced – especially for those offsite habitats which are outside the fenced cemetery and

the attenuation pond.

6. The minimum period the LEMP/HMMP will be in place needs to be specified.

7. The Ecological Mitigation Proposals report dated March 2023 should be annexed to the

LEMP.

8. The approved Construction Environmental Management Plan (CEMP) should be annexed to

the LEMP/HMMP.

9. A proforma of the agreed Grazing Licence should be annexed to the LEMP/HMMP so that it

serves as a model for all future grazing licences when they come to be renewed.

10. The proposed LEMP/HMMP, CEMP, SMC and proforma Grazing Licence should be published

on the planning portal so that all stakeholders have an opportunity to comment.

11. Arrangements need to be made for the possibility that the grazier is no longer the farmer

of Yew Tree Farm or where the farming practices at Yew Tree Farm become no longer

aligned with the requirements of the LEMP/HMMP.

12. Neither the LEMP/HMMP nor the CEMP can be finalised until the results of the planned

Dormouse survey are known, hopefully later this autumn.

13. The Grazing Licence needs to specify the months when cattle may be grazed on the

LEMP/HMMP land.

14. The Grazing Licence needs to identify how the obligations imposed on the grazier under

the LEMP/HMMP will be monitored. In particular, the requirement that no fertilisers or

herbicides should be used on any area of grassland and that cattle should not be treated

with wormers needs to be monitored to ensure compliance.

15. There is a contradiction between the 100% scrub removal proposed in the SMC and

LEMP/HMMP at Objective 2 which states that ‘Coverage of dock and thistle species, stinging

nettles and tall umbellifers should not exceed 5% in any one field ... The aim of this

management is not to remove scrub entirely from the SNCI – scrub provides a valuable

habitat for birds in particular – but to return the balance of habitats closer to the state

that it was in when the SNCI was originally designated.’ This needs to be resolved.

16. Who will bear those costs associated with Objective 2 which fall outside the management

of onsite habitats?

17. Objective 2.4, ‘Cut back bramble and other scrub from the areas outlined in red on the

plan below, using a tractor-mounted flail’, requires a Method Statement.

18. There is no practicable way to police Objective 2.8 – ‘Provide appropriate support to the

grazier, for instance in measures to ensure that dogs do not become problematic, using

6 https://www.gov.uk/guidance/register-a-biodiversity-site-and-allocate-to-a-development.

Comments on Draft LEMP – 09 April 2024

3

the sign boards at 10.1 to encourage appropriate use of the site.’

19. Objective 6 – a copy of the proposed CEMP needs to be provided.

20. Will the ecologist referred to in the Work Planner be an employee of the Council or an

independent contractor?

21. The contractor identified in the Work Planner at section 3.5 should be appointed in

consultation with the retained ecologist.

22. Sections 11.1 & 11.3 of the Work Planner should include the retained ecologist.

Comments on Draft LEMP – 09 April 2024

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Annex 1 – Headline Results comparison of BNG 4.0 and the SMC biodiversity

gain calculations

The impact of this will make Bristol's last working farm unviable. And the felling of treeswill undoubtedly affect this Site of Nature Conservation Interest.

It's time the City allowed the owners of Yew Tree Farm do what they do best without having tofight for what's right.

I am writing to object to the expansion of the crematorium by taking away land that hasbeen used by Yew Tree Farm, Bristol's last working farm.

It time to celebrate the work of Yew Tree Farm and not decimate . the lack of burial space is aNational Issue.https://researchbriefings.files.parliament.uk/documents/SN04060/SN04060.pdfhttps://www.theguardian.com/society/2022/dec/26/call-allow-reuse-graves-burial-plots-run-low-england-walesFrom my understanding, graves are not owned by the family, so how many people are still payingor not paying,

As a National Issue I would suggest the Council looks at this across the whole of the City Thereare many options available, further afield or maybe within the City on a bus, or cycle route .

I strongly object with the decision to expand South Bristol cemetery over areas 3 and 4(only) which is both SNCI land and a prominent hillside as per adopted local plan.

The council has been aware for many decades that burial spaces would eventually run out, yethere we are sacrificing important wildlife habitats and corridors for a temporary solution. It's notgood enough.

The land for a cemetery was earmarked as far back as the 1940s. At some point between thenewly built 1960s crematorium and The Greater Bristol Nature Strategy in 1991 sites 3 & 4 weredesignated not just 'city-wide importance' for nature but 'county-wide'. Only a handful of sitesacross the old administration of Avon were granted this designation showing how important it wasconsidered for the local flora & fauna.

Given that the council has always been on the SNCI selection panel it is bizarre that no-onethought to consider how the land would be dug up for new burial plots in the distant future.Logically, therefore, it must've been believed that the local polices (currently DM19) would be itsprotection from any cemetery encroachment or other development.

The Avon Wildlife Trust is another member of the original and current SNCI selection panel. Theyare very much against the plans and despite recently remaining quiet on council decision makinghave been unusually loud in this case. This speaks volumes about the importance of the land.

The ecological mitigation report claims the impact on grassland will be minor. This is implausible,

considering that 1,981 burial plots and several paths will cover 90% of area 3 and SUDS over area4. Grave digging and giant ponds are not known for their minor impact on soil and grassland.

By moving forward with these plans, it seems that the council is simply kicking the can down theroad for their successors to deal with. Nature does not have the luxury of time.

On the matter of time - it is unclear whether they will provide burial space for 15 or 25 years, thedata has not been made clear. This lack of transparency raises further doubts about the wisdom ofthis decision.

The ecologist remarked in one report how very well the long-established farmer, CatherineWithers, manages the land under her remit - be it leased or otherwise. The council would do wellto follow her example. The uniqueness and value of this site should be treasured and show theWorld that Bristol takes care of it's heritage and natural World and is innovate and forward thinkingenough to come up with alternative locations for burial sites - this problem isn't going away.

Lastly, approving this planning application (for sites 3 & 4) would be contrary to the councils ownpolicy DM19 and set a terrible precedent to developers who will rightly believe that any area ofBristol is up for grabs considering Bristol green policies are nothing more than green-washing ifthis application is fully approved.

Thanks.

I object to proposed expansion of crematorium as I believe it will harm the environmentof one of the last natural areas left in the city. These green spaces should be left undeveloped.

I wish to object to the cemetery expanding into Yew Tree farm. The farm has been therefor many years and is the last working farm in Bristol.

It is a very important site for wildlife due to the nature friendly operation of the farm and givesmuch needed habitat to a variety of species. In a time of ecological emergency acknowledged bythe Council itself there should be no disturbance on this land or taking away part of the farm as itwill destroy wildlife homes of which we need more not less.

The farming land left if the cemetery expansion goes ahead will make the farm unviable as it willbe too small. Whilst acknowledging that more burial spaces are needed the Council must considerother less damaging alternatives. The farm land has SNCI status and is formally acknowledged tobe an important site for nature due to the variety of species to be found there so it is ridiculous thata protected site should not be safe from development.

The Council says it wants to manage 30% of its land for wildlife and yet is considering destroying anature rich habitat home to bats, barn owls, badgers, foxes, kestrels, buzzards, bullfinches, siskin,starlings, many species of butterflies and pollinators and even otters who use the brook at thebottom of the farm.

The expansion of the cemetery if it goes ahead will result in the loss of high value wildlife habitatsand unfortunately will also lead to a decline in wildlife across the wider site due to shrinking andreducing the connectivity of habitats across the landscape and linking the farm to the widercountryside.

The farmer Catherine Withers has been treated very poorly and has faced threats to the farm forseveral years now.

I ask the Council to not expand the cemetery into the farm, to give the farm and wildlife there longterm security and to look elsewhere for suitable land for burials that won't destroy our green beltand SNCI sites. Thank you.

I've read pretty much all the objections and agree with many of the sentimentsexpressed. I've also read some of the supporting documents including various ecologicalassessments so appreciate the time and expertise spent in compiling them. Although I've missedthe opportunity to ask questions in person, this submission does contain some questions that, Ihope, councillors and the planning department will take into account.

In addition, rather than repeat objections previously voiced and with which I'm in agreement, Ihave additional concerns that there appears to be a disregard for the importance of scrub andscrub mosaics - the latter being very much applicable to the land at Yewtree Farm - in both thepresent and future ecological assessments and forthcoming BNG issues.

To counteract this, I hope councillors and the planning department will have time to take notice ofthe relevant paragraphs on the importance of scrub and scrub mosaics quoted from theDepartment for Environment, Food & Rural Affairs website blog on farming.

Questions:(1) Dormice: Since there now seems to be a chance that dormice might be on site and within thearea affected by the works, will you assure us that a thorough survey is done to establish if theyare indeed present. But we must be mindful that if there are any dormice present, they will be inhibernation, curled up on the ground in a nest and thus undetectable until April (depending on theweather).(2) Conservation Grazing: Since the grazing regime post development appears to key to both thegrassland management and the health of the lesser and greater horseshoe bats that use this land

- who has been in touch with Catherine Withers, the key steward of Yewtree Farm, to discuss thefeasibility of such a regime? Lesser and greater horseshoe bats need dung beetles so a limitednumber of cows that are not treated for worms are necessary to provide incomparable foragingopportunities.

The value of scrub and scrub mosaics:https://defrafarming.blog.gov.uk/manage-scrub-and-scrub-mosaics/

"Scrub is an invaluable wildlife habitat. It provides a variety of species with food and shelter andhas the greatest benefit where:- there is a variety of native species of shrubs like hawthorn, blackthorn and hazel- it has a range of heights, ages and structures- it grows in a mosaic with tall grass or other vegetation and flowering herbs, like thistles, ragwort,hogweed and black knapweed- it has edges that flow naturally into surrounding vegetation- scrub and mosaic vegetation, like grasses and herbs, flower and set seed to produce new habitat- occasional open grown trees develop through thorny scrub and bramble- shrubs develop standing or fallen dead wood

Defra's advice is to aim for scrub and scrub mosaics across 2 - 10 % of the farmed landscape.Since scrub and scrub mosaics like this are inn short supply across the farmed landscape in SouthBristol, Long Ashton and Dundry, surely it's important to value the scrub and scrub mosaics here.Again to quote from Defra's blog on scrub and scrub mosaics, the benefits created include:

- A habitat rich in invertebrates, reptiles, amphibians, small mammals and birds- Habitat that supports natural predators of crop pests and diseases- forage for livestock later into the year than other grazing habitat, like grassland- A buffer other habitats like water bodies, farm woods and priority habitats- A boost populations of pollinators- Support lichen communities, which provide food and nest material for wildlife- Helps remove carbon from the atmosphere- Maintains carbon-rich soils

These paragraphs sum up the value of Yewtree Farm as a wonderful place for wildlife and anincomparable place within Bristol City for people to take time out and revel in an unusually rich andwonderful wild place.

As a near neighbour and frequent visitor, I've enjoyed seeing birds, mammals, butterflies andother species foraging and sheltering in this unique scrub mosaic and wood pasture land, so I amdismayed to see it apparently dismissed as of little value. We all love the picture-postcard species-rich grassland meadows but a mix of grasslands, scrub mosaic, ancient hedge lines and veterantrees give so many chances for a variety of species to thrive.

To summarise: we should all know that wildlife populations are in steep decline, the climate crisisis accelerating and the future looks bleak for us all unless we can profoundly change our prioritiesand put the environment first. If we continue to dismiss the planet's life support systems as animpediment for growth and increase our human footprint, we are accelerating down a slipperyslope very fast indeed.

My objection is that this expansion will make Yew Tree Farm unviable, will kill maturetrees and build over an SNCI

We have read the Supporting Strategic Statement (10th November 2023) and theCommittee Report released on the same date. We also recognise the hard work by manyrespected organisations that has gone into assessing the application. So we fully understand thepressure on Bristol City Council. However as concerned citizens, we know pressures such asthese will only increase over time so we are still concerned about the relative short-term benefitsof the development when compared to the larger risks posed by climate change and biodiversityloss.

No land exists in isolation and Yew Tree Farm is not only linked to areas of significant importanceto biodiversity, wildlife and landscape coherence but, in its own right, it is it a jewel in the crown ofBristol's contribution to addressing the climate and ecological crisis. As such the decision you areconsidering has huge consequences not just for the residents of Bristol and their descendants.

As an organisation that is aware of the increasing severity of the planetary crisis, members of theLong Ashton Nature, Community and Environment Trust is, presumably like Bristol City Council,working to maintain and increase biodiversity loss in order to mitigate the adverse impacts of theclimate and ecological crisis. As part of our remit, we are keen to establish baseline data in orderto assess our impact, whether negative or positive, in the years to come. As a result, we've carriedout citizen-science surveys on bats and butterflies in several key areas including Yewtree Farm.The results of these recent surveys include the potential presence of dormice (see commentsbelow and location on map attached), rare bat species and one of the highest concentrations ofbutterflies in both South Bristol and Long Ashton.

First, we want to highlight that Yewtree Farm is a rich mosaic habitat with wood pasture, speciesrich hedge lines and veteran trees. It is also highly accessible for members of the public andCatherine Withers must be commended for her role in educating the community with her warmwelcome to walkers, bird watchers and others. In this instance, maybe the planning departmentand the council itself has, despite claims to the contrary, under-valued her invaluable contributionto the city, region and community.

Despite the Supporting Strategic Statement, we believe you still have an opportunity to re-evaluatethe generational importance of honouring the council's own declaration of a climate and ecologicalcrisis and ensuring many residents still have access to such rare, high quality green and bluespace right on their doorstep.

Please take into account the following:

(A) We are alarmed at the pressures that are increasing around Yewtree Farm and believe it iswithin the scope and power of Bristol City Council to show leadership in the present circumstancesand accountability to future generations in protecting Yew Tree farm.(B) We are all aware that Yewtree Farm has lost the tenancy of the hay-meadow in front of thefarm due to the advice of land agents, David James, to the investment company (LongmoorLand/Newcore Investments).(C) As a result, there has been the unwarranted creation of a gated entrance through an ancientand historic boundary hedge line. The worry, of course, is that a change in agricultural use of thisland will result in the loss of SNCI status and soon after this, an application will be put in for ahousing development.(D) Take this in combination with the pressures mounting from the cemetery expansion and thefuture of a wildlife-friendly farm is truly in jeopardy.

With note that some of the danger to Yewtree Farm comes from the unchecked influence of profit-focused property development companies on Green Belt land within the North Somerset/SouthBristol area. This has little to do with addressing the need for social housing let alone theimpending climate and biodiversity crisis. It is not enough that our property development sector isyears behind our comparator countries but, in these cases, there is very little independent baselineecological cost surveying done except those consultants paid by the development companies.

Council members and officers will be well aware of the dangers of conflicts of interest since thetwo major political parties, in particular, still receive considerable funds from companies withvested interests that lead them to ignore the real danger of climate change and biodiversity loss.Since climate change is progressing at least 30 x faster than at any time during the past 2.6 millionyears, we are all facing a very dangerous and uncertain future.

Before moving onto our survey information, we want to pass on these quotes to both councillorsthat are particularly engaged and supportive of the Biodiversity Net Gain policy as well as those

who are not:

(1) The United Nations Environment Programme Finance Initiative states that 'the business casefor biodiversity & ecosystem systems is not just about conserving endangered species. It isbecoming an issue of global policy that the benefits provided by biodiversity are valued andaccounted for within traditional business risk frameworks.(2) In 2021, the Environmental Audit Committee recognised in its final report "Biodiversity in theUK: bloom or bust" that Environmental Net Gain was a far better measure to implement comparedto the limitations imposed by Biodiversity Net Gain. (3) The Natural Capital Committee outlined inits report commissioned by the Government that "Delivery of net zero will be come incrediblydifficult, if not impossible, without environmental net gain".

Taking all this into account, we would urge Bristol City Council to instigate a minimum 10% BNGcommitment in its Local Plan as soon as possible

SURVEY INFORMATION

(i) Bats: As part of the North Somerset Bat Survey 2023, the LANCE Trust carried out nine batsurveys from end of August-beginning of November 2023 using the methodology laid out by theBat Conservation Research Lab at the University of Bath.. In addition, a Bat detector wasdeployed for six nights on two locations (Point B & C) within the area we know as Yew Tree Farm.Data was submitted to the BTO Acoustic Pipeline and survey results analysed and returned to us.Results in bold are additional to those included in the report from Wessex Ecological Consultancyalthough Myotis sp are hard to identify:

Point C: 18 - 24 September 2023 (just under 400 m west of Point C)Serotine, Myotis sp (inc Brandt's, Daubtenton's, Whiskered (low confidence), Natterer's), Leisler,Noctule, Nathusius', common and soprano pipistrelle, lesser and greater horseshoe, brown long-earedSpeckled, dark and Rosel's bush cricket, wood mouse, dormouse (low confidence signal),common and pygmy shrew.

Point D: 24 - 30 September 2023 (closest to cemetery expansion)Serotine, Myotis sp inc Brandt's, Daubenton's, Leisler, Noctule, Nathusius', common and sporanopipistrelle, brown long-eared, lesser horseshoeLong winged, speckled and dark bush cricket, dormouse, common & pygmy shrew and brown rat

These results indicate that....

(ii) Dormice.We understand that acoustic signals for dormice are hard to substantiate. However, it's worthpointing out that signals for dormice were recorded for all six nights that the detector was

deployed. Most of which were high confidence with two at over 0.9.

In total, there were 30 recordings of which 7 were above 60% in confidence; 40 % of recordingswere above .7 confidence, 46% above .6 and 73% above .5.

An expert in the BTO acoustic recording is presently analaysing the original recordings in order todetermine if dormice are present. The dormouse population, an endangered red list species, isdecreasing rapidly. A small, relict population of dormice here would need higher levels ofprotection than that currently offered.

(iii) ButterfliesHaving surveyed over 80 sites on the edge of South Bristol and Long Ashton, Barrow Gurney andDundry for Butterfly Conservation's Big Butterfly Count in 2023, we can confirm that Yewtree Farmis the most important agricultural site in South Bristol and Long Ashton. Bearing in mind, it's just a15 minute survey over five sites within the farm by two observers on one unfortunately rainy day in2023, 54 butterflies were recorded including common blue, gatekeeper, green-veined white, hollyblue, large white, meadow brown, red admiral, small white and speckled wood. The speciesdiversity represents the range of habitats and its important to note that, due to the weather, manybutterflies were flying or resting within the island pockets of bramble or bramble thickets adjacentto woodland.

(iv) BirdsMany people visit Yewtree Farm to birdwatch; and we are no exception it's no surprise butwelcome none the less to see that Wessex Ecological Consultancy noted a 'Notable increase invariety of bird species in the majority of hedges from 2001 - 2019/20'

(v) MammalsAmong the larger mammals, there are records of badgers, foxes, and deer whilst a still of an ottertaken a year or so ago by an infra-red trail camera on a small rock in Colliter's Brook gained muchtraction on social media

This is a disgraceful and poorly-thought out expansion. No other sites have beenassessed or even considered - because Bristol City Council yet again only see the easy route ofdestroying an SNCI and destroying the livelihood of our last remaining farm, thus impoverishingthe environment around this site as well.There are innumerable 'wasteland' Council-owned sites in nearby Hartcliffe & Whitchurch thatcould be converted and would support those local communities far more than destruction of anSNCI.

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SOUTH BRISTOL CEMETERY AND POTENTIAL EXTENSION AREA

ECOLOGICAL REPORT

1 INTRODUCTION The purpose of this report is to report on surveys to establish the nature conservation value of areas of farmland adjacent to the existing cemetery, including areas which might form an extension to the cemetery. Most of the area surveyed lies within a Site of Nature Conservation Interest (SNCI) and the survey has been extended to cover the existing cemetery in order to identify opportunities here to mitigate any adverse impacts associated with the proposed extension. 2 METHODS Site surveys were carried out on 29th November 2019, 12th June 2020, 18th June 2020 and 10th September 2020. They covered vegetation types and both vascular and lower plants; insects; and birds. Field 5, on the western edge of the area, was included in order to inform enhancement proposals. Grassland areas were surveyed to a level of detail that allows determination under the National Vegetation Classification (NVC); this involved identifying areas of homogenous vegetation and surveying five 4m2 quadrats in each, assessing percentage cover of each plant species present in the quadrats. The site was checked for badger setts and other signs of badger activity. Trees were checked, using binoculars as necessary, for holes, crevices and dense growths of ivy that might support roosting bats. Habitat quality for other protected species was assessed. Bat activity surveys have been carried out over the summer of 2020. Trees were checked to establish their potential for bat roosts. Three transect surveys were walked across around areas 1 and 6 and across parts of the cemetery during each month from June to August inclusive. Automated bat detector surveys were carried out three times per month across the same period, also covering areas 1 and 6. Due to the assumed scope at the time of survey area 3 was not covered by the activity surveys, although it was included in the bat roost assessment.

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Map 1: Transect routes The site had also been surveyed by Wessex Ecological Consultancy in August 2001 and 2010 and also (with the exception of the cemetery and field 1) as part of Bristol City Council’s review of SNCIs in May 2007; information from these surveys has been used to inform this report. A data search has been carried out at Bristol Regional Environmental Records Centre (BRERC) who supplied details of protected and notable species and designated sites within 500m of the site boundaries. 3 SURVEY RESULTS The survey site consists of six fields and the existing cemetery. Four of the fields are on a north-facing slope on the western edge of Bristol; one is on the plateau above the slope; and one is to the east of the cemetery. The fields are separated by large hedges and are currently all grazed. The fields, with the exception of field 1, are all within a Citywide Site of Nature Conservation Interest (SNCI). The cemetery is dominated by mown grassland with scattered standard trees and several lengths of ornamental hedge. The cemetery is designated as a Wildlife Corridor. The fields proposed for the extension have been numbered 1, 3 and 4 on the proposals map; the other fields surveyed are numbers 2 and 5. 3.1 Vegetation: Agricultural Areas 3.1.1 Grasslands Field 1 is grazed by horses and its sward varies from very short and poached to tall depending on the intensity of grazing, which is controlled by internal fences. Over most

3

of the field the dominant grasses are perennial rye-grass (Lolium perenne), rough-stalked meadow grass (Poa trivialis) and creeping bent (Agrostis stolonifera). Frequent herb species include creeping buttercup (Ranunculus repens) and shepherd’s purse (Capsella bursa-pastoris). Plants present in smaller quantity include meadow barley (Hordeum secalinum), black knapweed (Centaurea nigra), ox-eye daisy (Leucanthemum vulgare), common fleabane (Pulicaria dysenterica) and common bird’s-foot trefoil (Lotus corniculatus); this group of species tends to be more frequent in the northern part of the field. The other fields to the west of the cemetery are grazed by cattle and have permanent grassland, generally dominated by a combination of common bent (Agrostis capillaris), crested dogstail (Cynosurus cristatus) and perennial rye-grass (Lolium perenne). The lower lying areas have patches of hard rush (Juncus inflexus). Some herb species, including ribwort plantain (Plantago lanceolata), common sorrel (Rumex acetosa) and white clover (Trifolium repens) are frequent throughout. The fields tend to become more diverse on the steeper slopes towards their southern end. Variation between the fields is as follows: 2: This is a largely flat field on a plateau above the slopes. Most of the western part of the field is species-poor. The rest of the field is more diverse and species present include upright brome (Bromopsis erecta), common bird’s-foot trefoil, meadow vetchling (Lathyrus pratensis) and meadow barley, with rare grass vetchling (Lathyrus nissolia) and corky-fruited water dropwort (Oenanthe pimpinelloides). The western fringe of the field is species-rich in places and has a small population of pyramidal orchid (Anacamptis pyramidalis). 3: The northern part of the field has moderately species-rich grassland, with small quantities of species such as common bird’s-foot trefoil and meadow vetchling (Lathyrus pratensis). The slopes in the southern end of the field is more diverse and additional species here include glaucous sedge (Carex flacca), cowslip (Primula veris) and bugle (Ajuga reptans). 4: The lower part of the field has extensive areas of hard rush and locally frequent ox-eye daisy. The slopes in the southern part of the field support agrimony (Agrimonia eupatoria), common bird’s-foot trefoil, bugle (Ajuga reptans), meadow vetchling (Lathyrus pratensis), cowslip and the fungus meadow waxcap (Hygrocybe pratensis). The north-western corner of the field has a small copse that has developed around a former field pond, which is now silted up. Tree and shrub species here include crack willow (Salix fragilis), sallow (Salix cinerea), blackthorn (Prunus spinosa), field maple (Acer campestre), elder (Sambucus nigra), plum (Prunus domestica), hawthorn (Crataegus monogyna) and bramble (Rubus fruticosus agg). 5: The lower part of the field is more diverse than the corresponding parts of fields 3 and 4, with additional species including agrimony and black knapweed. The southern slopes are also more diverse than those in the other fields with meadow vetchling, devil’s-bit scabious (Succisa pratensis) and cowslip as well as the mosses Pseudoscleropodium purum and Rhytidiadelphus squarrosus and the fungi meadow

4

waxcap, cedarwood waxcap (Hygrocybe russocoriacea), snowy waxcap (Hygrocybe virginea) and scarlet waxcap (Hygrocybe coccinea). Field 6 is grazed by horses. Where grazing pressure is heavy much of the ground is bare and ruderal species such as common ragwort (Jacobaea vulgaris), common burdock (Arctium minus) and spear thistle (Cirsium vulgare) are frequent. In the western parts of the field grazing pressure is lighter and grassland species including ox-eye daisy, black knapweed and common bird’s-foot trefoil are frequent. 3.1.2 Hedges

The table overleaf summarises the composition of the hedges:

5

Hedge Number

Structure Standard Trees

Shrubs Woody Species in 30m length

Associated Features

A c2m tall, c1m wide

None Laurel None None

B c3m tall, c4m wide

Several semi-mature trees

Hawthorn, ash, field maple, blackthorn, apple, hazel, dogwood, pedunculate oak, English elm, field rose

Hawthorn, ash, field maple, blackthorn, hazel, dogwood, pedunculate oak, English elm (8 spp)

Hedge bank

C c4m tall, c5m wide

Immature ash

Hawthorn, hazel, ash, field maple, elder, blackthorn, wild privet, dog rose

Hawthorn, hazel, field maple, elder, blackthorn, wild privet (6 spp)

Hedge bank

D c1.5m tall, c3m wide

None Hawthorn, blackthorn, ash, elder, field maple, wild privet, hazel, holly, dog rose

Hawthorn, blackthorn, ash, field maple, hazel, holly, dog rose (7 spp)

Hedge bank

E c4m tall and c2m wide

Immature ash and English elm

Hawthorn, English elm, blackthorn, ash

Hawthorn, English elm, blackthorn (3 spp)

F Scattered scrub

None Hawthorn, English elm, balckthorn

Hawthorn, English elm, blackthorn (3 spp)

G Scattered bramble

6

Hedge Number

Structure Standard Trees

Shrubs Woody Species in 30m length

Associated Features

H Thick belt of scrub up to 15m tall

Immature ash and field maple

Hawthorn, field maple, hazel, blackthorn, dog rose

n/a

I Belt of bramble

Immature silver birch in cemetery

Bramble n/a

J c4m tall and c3m wide, dense

Small crab apple

Hawthorn, blackthorn, ash, elder, dog rose, crab apple, hazel

Hawthorn, blackthorn, ash, elder, dog rose, crab apple (6 spp)

Cuckoo-pint, dog’s mercury, wood false-brome

H c6m tall, c6m wide

Semi-mature ash and pedunculate oak

Hawthorn, hazel, spindle, blackthorn, field maple, dog rose

Hawthorn, hazel, pedunculate oak, ash, blackthorn, field maple, dog rose (7 spp)

Hedge bank

I c8m tall, c6m wide

Semi-mature pedunculate oak, immature ash, sallow, field maple

Hawthorn, blackthorn, hazel, spindle, dogwood, sycamore, elder, horse chestnut, dog rose

Hawthorn, blackthorn, hazel, spindle, dogwood, pedunculate oak, ash, sallow, dog rose (9 spp)

Hedge bank, stream

J c8m tall, c8m wide

Mature pedunculate oak

Blackthorn, hawthorn, hazel, alder, spindle, ash, field maple, elder, English elm, dog rose

Blackthorn, hawthorn, hazel, pedunculate oak, spindle, ash, field maple, dog rose (8 spp)

Hedge bank

K c6m tall, c7m wide

Immature ash Blackthorn, hawthorn, dogwood, ash, field maple, dog rose

Blackthorn, hawthorn, dogwood, ash (4 spp)

Hedge bank

L Gappy scrub

Semi-mature ash

Field maple, hawthorn, blackthorn, dog rose

Ash, hawthorn, blackthorn, dog rose (4 spp)

M Line of trees

Leylandii, hybrid poplar, crack willow

Hawthorn, field maple

Hawthorn, hybrid poplar, crack willow (3 spp)

N Line of trees

Immature ash, field maple, lime

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Hedge Number

Structure Standard Trees

Shrubs Woody Species in 30m length

Associated Features

O Thick belt of scrub up to 15m tall

Immature ash and field maple

Hawthorn, field maple, hazel, blackthorn, dog rose

n/a

P Belt of bramble

Immature silver birch in cemetery

Bramble n/a

Q

c4m tall and c3m wide, dense

Small crab apple

Hawthorn, blackthorn, ash, elder, dog rose, crab apple, hazel

Hawthorn, blackthorn, ash, elder, dog rose, crab apple (6 spp)

Cuckoo-pint, dog’s mercury, wood false-brome

3.2 Vegetation: Cemetery 3.2.1 Grasslands Grassland is the dominant habitat type across the cemetery. Its composition varies significantly, but most areas are dominated by a mixture of perennial rye-grass, red fescue (Festuca rubra) and creeping bent. The most frequent herbs are common daisy, dandelion (Taraxacum vulgare) and white clover. The following plant species were recorded in the grassland: The grassland includes several patches of species-rich grassland, some characterised by frequent strawberry clover and others by a diversity of limestone grassland species, such as lady’s bedstraw (Galium verum), mouse-ear hawkweed (Pilosella officinarum) and common bird’s-foot trefoil. The distribution of these areas is shown on the attached map. There is a small area of tall grassland in the north-eastern corner of the cemetery, which is dominated by false oat-grass (Arrhenatherum elatius), cocksfoot (Dactylis glomerata) and red fescue, with small patches dominate by common bent. Herb are not generally diverse but black knapweed is locally frequent. In 2010 the area of tall grassland was both more extensive and more diverse and several species not found in 2019, including common fleabane, agrimony and pepper saxifrage (Silaum silaus) were recorded. In 2000 it was more diverse still and species that have disappeared since then include sneezewort (Achillea ptarmica), devil’s-bit scabious and conglomerate rush (Juncus conglomeratus). 3.2.1 Hedges, Trees and Shrubs The cemetery has reasonable numbers of immature and semi-mature trees, which include ornamental cherries (Prunus spp), Swedish whitebeam (Sorbus intermedia), and downy lime (Tilia tomentosa). Many of these trees support prolific growth of epiphytes, including lichens such as Physcia tenella, Parmelia sulcata, Melanelixia subaurifera and Melanelixia glabratula; and bryophytes such as Metzgeria furcata, Frullania dilatata and Cryphaea heteromalla. A thorough fungus survey has not been carried out, but there are several species of interest associated with trees around the

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site; these include terracotta hedgehog (Hydnum rufescens) and solitary amanita (Amanita echinocephala). There are several hedges around the cemetery as follows: i) A belt of dense tree-planting, which includes ash, English elm, pedunculate oak (Quercus robur) and field maple.

ii) This edge of the cemetery has a dense strip of mixed blackthorn and bramble scrub.

iii) A low hedge consisting of dogwood, hawthorn, wild privet, blackthorn, dog rose and bramble.

iv) Line of tall cypress trees.

v) Low mixed hedge of hawthorn, wild privet, dogwood, field maple and bramble.

There are two mature trees of pedunculate oak (Quercus robur) in the northern part of the cemetery, one within the tree-planting belt at i) and one just to the north.

The north-eastern corner has an extensive area of bramble scrub, which has developed on the species-rich grassland that was present here in 2000.

3.3 Birds: Agricultural Areas No birds were seen in the fields in 2001, but swallow was feeding over all of the fields in 2010. The following species were seen in the hedges:

Hedge no.

2001 2010 2019/20

B Wren, robin Chiffchaff, long-tailed tit, robin

Wren, dunnock

C Blue tit, long-tailed tit, magpie

Blackcap, chiffchaff Dunnock, robin, wood pigeon, lesser whitethroat, greenfinch, wren, bullfinch

D Wren Dunnock

E Blue tit, robin, wood pigeon

Robin Greenfinch, robin, wren, song thrush, great spotted woodpecker

F Blackbird Blackbird

G Blue tit, robin Blackbird

H Greenfinch Blackbird, blue tit, bullfinch, wood pigeon, wren, dunnock, chiffchaff, blackcap, green woodpecker, goldfinch, jay

I Blackbird, blackcap, blue tit

Bullfinch, chiffchaff, dunnock, goldfinch, magpie, wood pigeon

Blackbird, blue tit, bullfinch, dunnock, goldfinch, magpie, jay, robin, greenfinch, chiffchaff, blackcap, great spotted woodpecker

J Blue tit, willow warbler, wood pigeon

Sparrowhawk, wood pigeon

Blackbird, bullfinch, sparrowhawk, wood pigeon, chiffchaff, dunnock, great tit

K Blackbird Blue tit, greenfinch, long-tailed tit, robin, wren

Blackbird, robin, wren, chiffchaff, chaffinch, blue tit

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Hedge no.

2001 2010 2019/20

L Magpie Greenfinch Chaffinch

M Blackbird, blue tit, chaffinch, dunnock, greenfinch, magpie, song thrush

N Chaffinch, dunnock, greenfinch, robin, song thrush

O Blackbird, blackcap, dunnock, greenfinch, robin

P Carrion crow, greenfinch

Q Blackbird, blue tit, chiffchaff, dunnock, greenfinch, robin

Scrub in field 4

Blackbird, robin

Blackcap, blue tit, dunnock, whitethroat, wren

Blackbird, blue tit, bullfinch, wood pigeon, wren, lesser whitethroat

A bird list was included in the 2007 report, but this survey covered a wider area and the location of records was not specified. 3.4 Birds: Cemetery Large numbers of birds were noted in the main area of the cemetery during the 2019/2020 surveys: herring gull, lesser black-backed gull, black-headed gull, carrion crow, raven, dunnock, wren, robin, blackbird, redwing, song thrush, mistle thrush, starling, blue tit, great tit, long-tailed tit, goldcrest, blackcap, chiffchaff, pied wagtail, greenfinch, goldfinch and chaffinch. Tawny owl and buzzard were present in the woodland belt on the northern edge of the cemetery. In 2010 the following were recorded: pied wagtail, swallow, goldfinch and linnet, with whitethroat in the scrub in the north-eastern corner of the cemetery. 3.5 Insects: Agricultural Areas Species recorded in the fields are listed in Appendix 3. They include grassland specialists such as marbled white and common blue butterflies; burnet companion and Grapholita compositella moths; and Chrysotoxum bicinctum and Lepidogaster cylindrica flies, as well as several species of bee. The following species were recorded in the hedges: A: Speckled wood butterfly and dark bush-cricket (2001); gatekeeper and holly blue butterflies (2010).

C: Gatekeeper and speckled wood butterflies (2010).

J: Gatekeeper and speckled wood butterflies (2010).

Scrub in field 4: Holly blue butterfly and vapourer moth (2010).

3.6 Insects: Cemetery The only insect recorded in 2019 was the micro-moth Gracillaria syringella, in hedge v). The following were recorded in 2010 and in 2020:

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Short grassland areas - common blue butterfly and Agriphila straminella moth.

Tall grassland area - peacock, meadow brown and common blue butterflies; Udea lutealis and Chrysoteuchia culmella moths; and long-winged conehead and meadow grasshopper.

Trees – speckled wood butterfly; light emerald, Ypsolopha ustella and Stigmella continuella moths; Kelidocerys resedae and Blepharidopterus angulatus bugs; and Colletes hederae bee.

3.7 Protected Species: Agricultural Areas Badger foraging signs were seen in fields 4 and 5 but no sett was found. A grass snake was seen on the northern edge of field 4 in 2010. The only tree with potential as a bat roost was in area 4. All of the trees in and around the potential extension areas had negligible potential for roosting bats. Six species of bat were recorded during the transect surveys: common pipistrelle, soprano pipistrelle, lesser horseshoe, serotine, noctule and Myotis sp. The most commonly recorded species was common pipistrelle, accounting for over half of the bats recorded. The highest levels of activity were recorded along the southern edge of area 1, with low levels in area 6 apart from along its eastern boundary, and moderate levels in the existing cemetery. Eight species were recorded during the automated surveys: common pipistrelle, soprano pipistrelle, lesser horseshoe, greater horseshoe, brown long-eared, serotine, noctule and Myotis sp. There were over twice as many bats recorded in area 6 as in area 1. Common pipistrelle was again the most commonly recorded species, followed by noctule and serotine. Activity levels of the other species were very low. The figure below shows the results of the transect surveys (numbered as on map 1 above).

Further details are given in the Assessment section below. 3.8 Protected Species: Cemetery Badger foraging signs were seen in the northern and western parts of the cemetery. No sett was found.

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Further details are given in the Assessment section below. 3.9 Data Search Most records that BRERC holds from the survey site are taken from the 2000 and 2010 surveys recorded above. Other records from the site are as follows: Serotine bat, north-western part of field 5, 2003;

Small heath butterfly, cemetery, 1977;

Wall brown butterfly, cemetery, 1977.

BRERC holds records of protected species from the surrounding area as follows: Slow worm: c500m to the north of the site, 2001; c400m to the south-east of site, 1998;

Common toad: c500m to the north of the site, 2001;

Grass snake: c500m to the north of the site, 2001 (in addition to the record from the 2010 survey referred to above);

Common lizard: c500m to the north of the site, 2001;

Serotine bat: c400m to the south-west, 2002;

Pipistrelle bat sp: c400m to the south-west, 2002; c200m to the west, 2003; c100m to the west 2003; c200m to the north-west, 2003;

Daubenton’s bat: c200m to the west, 2003;

Noctule bat: c200m to the west, 2003; c100m to the west, 2003; c200m to the north-west, 2003;

Serotine bat: c100m to the north, 2004;

Lesser horseshoe bat: c100m to the north, 2004; c400m to the west, 2008;

Otter: c100m to the west, 2017 and 2018; c100m to the north, 2018.

Approximate locations of bat roosts in the surrounding area are: Pipistrelle sp: c300m to the north, 2004; c500m to the east, 2000;

Soprano pipistrelle: c300m to the north, 2004;

Brown long-eared: c500m to the east, 2000;

Noctule: c300m to the north, 2004;

Lesser horseshoe: c300m to the north, 2004.

Other records from the surrounding area include: Stoat, recorded in 2004 just to the north of the cemetery;

Hedgehog, which has been recorded in several gardens in the surrounding area as recently as 2018;

Red-tailed bumble bee (Bombus ruderarius), c400m to the north-east, 2001.

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There are also large numbers of records of bird and plant species from surrounding areas. 4 ASSESSMENT The nature conservation value of the site has been assessed to determine whether it is of nature conservation value in a national, regional or city-wide context, of either high or low value in a local context, or is of minimal nature conservation value. The assessment has been made using standard ecological criteria, such as size, diversity, rarity and fragility. Reference has been made to suitable guidance, including the 2006 Natural Environment and Rural Communities (NERC) Act and the UK and Bristol Biodiversity Action Plans (BAPs). The value of the site for groups not surveyed, such as most invertebrates, has been assessed using information gathered on the nature and structure of the habitats present. The survey was carried out late in the season, meaning that some groups such as hedgerow ground flora could not be surveyed; this has been taken into account in making the assessment. 4.1 Grasslands The nature conservation value of grasslands generally depends on the extent to which they have been improved. The use of fertilisers or herbicides excludes almost all grassland plants. The resulting grassland, termed improved grassland, is of minimal nature conservation value, is readily recreatable and is widespread and common throughout lowland Britain. Grasslands that have not been treated with fertilisers or herbicides, or re-sown, are termed unimproved grasslands. They support a large range of plants (and therefore invertebrates) that have been excluded from almost all grasslands, in both urban and rural areas, and are recognised as a priority for conservation. Between these two extremes there is a large range of intermediate grasslands, termed semi-improved grassland, that have undergone a limited degree of intensification but continue to support a reasonable diversity of plant species. Their nature conservation value can be judged by the number of species characteristic of unimproved grassland, termed unimproved grassland indicator species, that they support. The more diverse examples of semi-improved grasslands approach unimproved grassland in species richness and are priority habitats. 4.1.1 Agricultural Areas The most diverse area of grassland surveyed is the southern part of field 5. The presence of species such as devil’s-bit scabious and a range of waxcap fungi indicates that the grassland here is either unimproved or, if semi-improved, approaches unimproved grassland in value. In NVC terms the grassland here is a matrix of MG5 Centaurea nigra-Cynosurus cristatus grassland of the Galium verum sub-community and MG6 Lolium perenne-Cynosurus cristatus grassland of the Trisetum flavcescens sub-community. This area is of nature conservation value in a citywide context. The grasslands in field 1; the southern parts of fields 3 and 4; the eastern part of field 2; the western fringe of field 2; and the western part of field 6 are slightly less diverse but they support a reasonable diversity of plants such as common bird’s-foot trefoil, meadow vetchling and ox-eye daisy that are indicative of unimproved grassland. In

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NVC terms these areas support MG6 Lolium perenne-Cynosurus cristatus grassland of the Trisetum flavcescens sub-community with patches of MG5 Centaurea nigra-Cynosurus cristatus grassland of the Galium verum sub-community on the steepest slopes. These areas are of high nature conservation value in a local context. The eastern part of 6, northern parts of fields 3 and 4 and the southern part of field 2 (with the exception of the western fringe of the field) are less diverse, although some plants associated with unimproved grassland are present. The least diverse areas appear to be in fields 2 and 3, whilst field 4 is slightly more diverse. The drier parts of these areas have MG6 Lolium perenne-Cynosurus cristatus grassland of the Trisetum flavcescens sub-community; the rush-dominated vegetation in the centre of the lower parts of fields 3 and 4 is an example of MG10 Holcus lanatus-Juncus effusus rush-pasture of the typical sub-community. These areas are of low nature conservation value in a local context. There is evidence that the botanical diversity of some of the grasslands, in particular field 2, has declined slightly since the 2001 and 2007 surveys in particular, possibly due to changes in agricultural management. 4.1.2 Cemetery Most of the grassland in the cemetery has been improved and in NVC terms is MG7 Lolium perenne-Plantago lanceolata grassland. It is of minimal nature conservation value. The more diverse areas, however, support semi-improved grassland that in places approaches unimproved grassland in its species diversity. In NVC terms this is MG6 Lolium perenne-Cynosurus cristatus grassland of the Trisetum flavcescens sub-community The presence of a large population of strawberry clover is of particular significance. This species has been included on the England red list of vascular plants with the status of vulnerable due to steep population declines. It has been lost from several other sites in Bristol. The areas of species-rich grassland shown on the attached maps are of high nature conservation value in local context. The grassland in the north-eastern part of the cemetery has declined significantly in nature conservation as some parts of the area have been incorporated into the cemetery and others have been unmanaged and colonised by bramble. It still retains several plant species indicative of unimproved grassland, including black knapweed, meadow vetchling and lady’s bedstraw. It is probably of some value for invertebrates since it has a mixture of short grassland, tall grassland and scrub. This area is of high nature conservation value in a local context.

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4.2 Woody Vegetation 4.2.1 Agricultural Areas A framework for assessing the nature conservation value of hedges is provided by the guidelines for identifying Important Hedgerows in the 1997 Hedgerow Regulations. The primary criterion in these guidelines is the diversity of woody species in a 30 metre length of hedgerow, which reflects both the age, and therefore difficulty of recreatability, and the wildlife value of the hedge. Other criteria include diversity of structure within a hedge, the presence of standard trees, the degree of connectivity to other hedges and the presence of associated features such as hedge banks. Most of the hedges surveyed here have a good structure and are dominated by native species, but the diversity of woody plants varies from hedge to hedge. The hedges’ dense structure and diversity of woody species indicate that they are likely to be of value for birds and invertebrates. The bird species recorded include priority species such as bullfinch, dunnock and song thrush. The hedges provide suitable habitat for a range of moth species that are included as priority species in Section 41 of the NERC act. Hedges B, C, D, H, I and J qualify as Important Hedgerows and are of nature conservation value in a city-wide context. Hedges E, K, L, and O are less diverse but they have a reasonable range of woody species and a good structure. They are of high nature conservation value in a local context. Boundaries A, F and G lack true hedges and are of minimal nature conservation value. The patch of scrub in field 4 supports a reasonable diversity of woody species and is of value for birds. It is of low nature conservation value in a local context. 4.2.2 Cemetery The most valuable trees within the cemetery are the mature oaks close to the northern boundary. These include features such as standing dead wood and sap runs that indicate that they are likely to be of significant interest for invertebrates. As ancient trees they are irreplaceable. The oak trees are of nature conservation value in a citywide context. The other trees in the cemetery are not of significant value if considered individually but collectively they provide good habitat, in particular for birds. Species of conservation concern such as song thrush, mistle thrush, dunnock and linnet and the presence of good numbers of chaffinch and greenfinch, both of which have undergone extreme population declines in Bristol, is of significance. Non-native species such as cypress add to the value of the site for birds, since they are favoured by species such as goldcrest, greenfinch and goldfinch. The trees are also likely to be of interest for insects and several Section 41 species of moth are likely to be present. The most valuable in this context are likely to be the silver birches and apple and cherry cultivars. The combination of a wide diversity of native and non-native trees and grassland

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managed without large inputs of chemicals indicates likely value for fungi. BRERC has only one record of solitary amanita from Bristol and none of terracotta hedgehog. The tree population of the cemetery is of high nature conservation value in a local context. 5.3 Protected Species Several parts of the site are of some value as badger feeding habitat; the areas with the greatest concentration of signs were the western part of the agricultural area, in particular in field 5, and the western part of the cemetery adjacent to hedge E. A grass snake was seen on the northern edge of field 4 in 2010, indicating that there is a population of this species in the area. The fields are too tightly grazed to be used by grass snakes, and the population probably uses the hedges and the copse in field 4, as well as habitats beyond the survey site such as the railway embankment and Colliter’s Brook. No potential bat roosts are present in the areas likely to be affected. Areas 1 and 6 are of low to moderate value for feeding bats, in particular pipistrelle species. There is as yet no information on the value of area 3. No dormice are known in the surrounding area and it therefore extremely unlikely that they use the hedges on the site. There are no records of great crested newt in the surrounding area and no potential breeding ponds are present on the site or, as far as could be seen, in the surrounding area. The habitats on the survey site are not potentially suitable for any other protected species. 5 IMPACTS 5.1 Habitats The areas within the cemetery that are proposed for burials do not have diverse grassland. The trees across some of these areas are of value for birds and other wildlife; the significant trees would be retained and those proposed for removal are without ecological value. There would be no adverse impact in these areas. Extension of the cemetery would involve incorporating areas of moderately species-rich grassland, a NERC act priority habitat, into the site. Use of a site for burials is not necessarily incompatible with grassland conservation: several parts of the existing cemetery support species-rich grassland, as do several other cemeteries in Bristol. However, the trends seen in the grassland area in the northern part of the cemetery show that this cannot be guaranteed and that appropriate management and planning would be required to ensure this. This area, which in 2001 supported a significant area of valuable grassland, has progressively declined in value through the surveys of 2010 and 2019.

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Retention of species-rich grassland would require appropriate management (a regular regime of mowing) until and after the area is brought into use; minimal construction of infrastructure such as paths; planning of works to avoid compaction; long term management without the use of fertilisers or herbicides. Even this regime, if it could be implemented, would lead to some habitat loss as creation of features such as paths is necessary and plot holders would control the management of graves themselves. However, it would reduce losses; use of a system such as meadow burials would reduce losses further. The current proposals would involve the loss of the lower part of area 3, and part of area 4 would be used as an attenuation pond. The areas of both fields that would be affected support species-poor semi-improved grassland and the more diverse areas of both fields would be retained. These proposals would not affect the most valuable areas of the SNCI, which would remain intact, but they would affect areas of grassland of interest for which the site is designated. The proposals would have a minor adverse impact on the SNCI. Much of area 1 would also be used for burials, although an area in the north-eastern part of the field would be retained. This field is not within the SNCI, but parts of the field have a comparable level of interest to that of the SNCI. The use of much of field 1 would have a minor adverse impact on the SNCI. The western part of field 6 is diverse and incorporation of this into the cemetery would have an adverse impact, unless this could be done in such a way that the grassland remains intact. The proposals do not involve significant loss of hedges and none of the species-rich hedges would be affected. The proposed access to area 3 uses an existing gap in the hedge and would involve only limited amounts of additional clearance. There would be no significant adverse impact on hedges. 5.2 Protected Species There would be no impacts on roosting bats. The hedge network would remain largely intact, which would avoid most potential impacts on commuting and foraging bats, since these are the parts of the site that are most heavily used by bats. There may also be some impact on foraging bats, including horseshoe species, where areas of grassland are incorporated into the cemetery. The grassland would remain available as foraging habitat but its value is likely to be reduced, as close mown grassland is unlikely to support significant numbers of foraging bats and because, in those parts of areas 3 and 4 that would be affected, cattle dung will no longer be available. The scale of these impacts is hard to quantify, because grassland is being modified rather than lost, but is likely to be minor. No lighting is proposed. No other potential impacts on protected species have been identified.

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6 MITIGATION The proposals have been designed to mitigate impacts as far as possible through measures including:

• Retention of significant trees.

• Retention of hedges in as intact a state as possible.

• Retention of the most important areas of species-rich grassland. Partial mitigation for the loss of grassland can be achieved through ensuring sympathetic management of areas proposed for burial, before they are brought into use, whilst burials are being carried out, and in the long term. No fertilisers or herbicides should be applied to any area of grassland. Management of areas proposed for incorporation should be remain as at present except in parts of fields 1 and 6 that are subject to heavy horse grazing. These areas would benefit from a less intensive grazing regime, or a hay cut. Cattle grazing should be continued across areas 3 and 4 for as long as possible. In the longer term it should be ensured that cattle continue to have access to retained parts of the two areas, including the northern part of area 3. Where areas are used for burials the existing turf should be retained between graves and measures should be taken to allow grassland regeneration on graves. It is likely that, in the short and medium terms at least, graves and surrounding areas will have to be mown short in order to provide a formal setting. It would, however, be beneficial to set blades slightly higher than at present to allow low-growing plant species to flower. The proposals include hedge and tree planting within the existing cemetery. Most of these would be beech hedges, which are favoured for providing a formal setting. Beech is a native species that has value for wildlife, and the hedges would be further enhanced by planting of small standard trees, including field maple and crab apple. There are also opportunities for additional tree planting elsewhere in the cemetery. There are some opportunities for mitigation for the loss of grassland through enhancement within the SNCI, although the existing high interest of many parts of the site limits the scope for enhancement. There are areas of less diverse grassland, as in area 2, which could be diversified through measures such as turf stripping and spreading green hay from more diverse parts of the site. The value of the SNCI for foraging bats could be enhanced by minor changes to the grazing regime, including using cattle that are not treated with wormers. This would result in the site supporting much larger populations of insect species that are important for horseshoe bats in particular.

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7 ENHANCEMENT The following enhancement measures are proposed:

• Securing appropriate management of grasslands (it appears that parts of the SNCI have received some fertilizer applications at some time over the last twenty years, resulting in a slight decline in botanical value).

• Revision of management of the grassland in field 6: the current horse grazing has damaged the sward and there is potential to enhance the diverse grassland in the western part of the field, and to return the eastern part of the field to a more diverse sward by reversing the effects of compaction and poaching.

• Creation of wetland habitat features around the attenuation pond. Appropriately designed and managed habitats would be of greater value than the grassland that they would replace and would add ecological diversity to the SNCI. This would include enhanced habitat for foraging bats.

• Provision of bird and bat boxes in trees, both in the existing cemetery and in extension areas.

• Planting trees and shrubs to improved ecological connectivity along the railway fence along the northern edges of fields 3 and 4, and along hedge A. These boundaries are currently partial gaps in the hedgerow network around the site. Planting along the railway fence would be particularly valuable as this is believed to be a strategically important corridor for commuting bats.

• Creation of microhabitats within the cemetery: examples include sparsely vegetated banks, preferably facing east or west, and stonework incorporating gaps suitable for use by leaf-cutter bees.

8 BIODIVERSITY NET GAIN Measures to ensure that the proposals achieve net gain have been explored. The proposals include the replacement of areas of semi-improved grassland with modified grassland, and much smaller areas of track and hard standing. This will result in a loss of biodiversity value. There are limited opportunities to offset these losses on site. In the cemetery operational objectives mean that major enhancement schemes are not possible. In the SNCI the high existing value of most of the site means that most areas cannot be enhanced above their current level. Discussions with the BCC Parks Department are therefore underway to identify opportunities for enhancement offsite.

Rupert Higgins Wessex Ecological Consultancy 5th May 2021

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Map 1: Areas mentioned in text

20

Map 2: Species-rich grasslands

21

Map 3: Wooded habitats

22

Map 4: Eastern area

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APPENDIX 1: PLANT AND FUNGUS SPECIES RECORDED IN FIELDS (TO WEST OF CEMETERY) For fields 3-5 column a) refers to the northern (lower) part of the fields and b) to the southern (upper) part of the fields.

Field Numbers

1 2 3a 3b 4a 4b 5 Notes

Grasses

Agrostis capillaris Common bent R R O O O OLF R

Agrostis stolonifera Creeping bent OLF O O R O R OLF

Alopecurus pratensis Meadow foxtail O R R R O R

Anthoxanthum odoratum

Sweet vernal grass OLF O O O O OLF

Arrheantherum elatius False oat-grass R R R RLF

Briza media Quaking grass O O GI

Bromopsis erecta Upright brome RLF OLF OLF GI

Bromus hordaceus Soft brome R R

Bromus racemosus Meadow brome RLF R GI, AN

Cynosurus cristatus Crested dogstail R OLF O O O O R

Dactylis glomerata Cocksfoot RLF R R R R R R

Festuca rubra Red fescue R R R R O R

Holcus lanatus Yorkshire fog O R R O O O

Hordeum secalinum Meadow barley OLF OLF R O R R GI

Lolium perenne Perennial rye-grass R O O R F R O

Phleum bertolonii Small cat’s-tail (R) GI, AN

Phleum pratense Timothy R R R R

Poa annua Annual meadow-grass

R R

Poa pratensis Smooth meadow-grass

R R R R R

Poa trivialis Rough-stalked meadow grass

OLF RLF

Schedonorus arundinaceus

Tall fescue R

Schedonorus pratensis

Meadow fescue R R R GI

Tristetum flavescens Golden oat-grass R O O GI

Herbs

Achillea millefolium Yarrow O RLF R

Agrimonia eupatoria Agrimony R R O GI

Ajuga reptans Bugle R R

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Field Numbers

1 2 3a 3b 4a 4b 5 Notes

Achillea millefolium Yarrow O

Agrimonia eupatoria Agrimony R R R GI

Anacamptis pyramidalis

Pyramidal orchid R GI, AN

Arctium minus Lesser burdock RLF

Bellis perennis Common daisy R R R R

Capsella bursa-pastoris

Shepherd’s purse R

Carex flacca Glaucous sedge R R R R GI

Carex hirta Hairy sedge R

Centaurea nigra Black knapweed RLF R R RLF GI

Cerastium fontanum Common mouse-ear

R R R O

Cerastium glomeratum

Clustered mouse-ear

R

Chenopodium album Fat-hen R

Cirsium arvense Creeping thistle R R R R

Cirsium palustre Marsh thistle R R R R O

Cirsium vulgare Spear thistle R

Convolvulus arvensis Field bindweed R R (R)

Crepis capillaris Smooth hawksbeard

R R

Dipsacus fullonum Teasel R

Galium verum Lady’s bedstraw (R) GI Geranium dissectum Cut-leaved

cranesbill R R R R

Geranium molle Dovesfoot cranesbill

R R

Heracleum sphondylium

Hogweed R R R R

Hypochaeris radicata Common catsear RLF R R RLF O

Juncus inflexus Hard rush RLF RLF

Lathyrus nissolia Grass vetchling R R GI, AN

Lathyrus pratensis Meadow vetchling R O R R R O GI

Leontodon autumnalis

Autumnal hawkbit R (R) R

Leontodon saxatile Lesser hawkbit RLF O R GI

Leucanthemum vulgare

Ox-eye daisy O RLF R O RLF O RLF GI

Linum catharticum Purging flax RLF GI

Lotus corniculatus Bird’s-foot trefoil RLF OLF RLF OLF RLF OLF RLF GI Luzula campestris Field woodrush R R O R GI

Lysimachia nummularia

Creeping jenny R (R) GI

25

Field Numbers

1 2 3a 3b 4a 4b 5 Notes

Medicago lupulina Black medick R R

Odontites verna Red bartsia RLF O

Oenanthe pimpinelloides

Corky-fruited water dropwort

R GI,AN

Ononis repens Creeping restharrow (R) RLF GI

Plantago lanceolata Ribwort plantain R RLF O O O F

Plantago major Rat’s-tail plantain O Potentilla reptans Creeping cinquefoil O R R RLF R OLF

Primula veris Cowslip R R O RLF GI

Prunella vulgaris Self-heal R R R R R O

Pulicaria dysenterica Common fleabane RLF GI

Ranunculus acris Meadow buttercup O O R R R O R

Ranunculus bulbosus Bulbous buttercup R R R R O O

Ranunculus repens Creeping buttercup O RLF O R O O F

Rumex acetosa Common sorrel R R R O R R GI

Rumex crispus Curled dock R R R R O

Rumex obtusifolius Broad-leaved dock R R

Senecio erucifolius Hoary ragwort O R GI

Senecio jacobaea Common ragwort R R R R R RLF

Sonchus asper Prickly sow-thistle R

Taraxacum vulgare agg

Dandelion R R R R R

Trifolium dubium Lesser trefoil R R R R R

Trifolium fragiferum Strawberry clover R R R R R GI, AN

Trifolium pratense Red clover R R R R O

Trifolium repens White clover R R O R O R O

Urtica dioica Stinging nettle R R

Veronica persica Common field-speedwell

R

Veronica serpylifolia Thyme-leaved speedwell

R R

Vicia sativa Common vetch R

Mosses

Amblystegium serpens

R R

Brachythecium rutabulum

R

Calliergonella cuspidata

F R O O F R R

Didymodon fallax R

Kindbergia praelonga O

Fungi

Hygrocybe pratensis Meadow waxcap R GI

Abundance codes: D – dominant; A – abundant; F – frequent; O – occasional: R – rare; L – locally. Bracketed species were recorded in 2010 but not 2020. Notes: GI – grassland indicator species; AN – Avon Notable Species.

26

Appendix 2: Plant Species Recorded in Cemetery Grasses Common bent Agrostis capillaris Creeping bent Agrostis stolonifera Sweet vernal grass Anthoxanthum odoratum False oat-grass Arrhenatherum elatius Upright brome Bromopsis erecta Crested dogstail Cynosurus cristatus Cocksfoot Dactylis glomerata Tall fescue Festuca arundinacea Red fescue Festuca rubra Yorkshire fog Holcus lanatus Perennial rye-grass Lolium perenne Small cat’s-tail Phleum bertelonii Timothy Phleum pratense Smooth meadow-grass Poa pratensis Rough-stalked meadow-grass Poa trivialis Golden oat-grass Trisetum flavescens Herbs Yarrow Achillea millefolium Bugle Ajuga reptans Common daisy Bellis perennis Glaucous sedge Carex flacca Black knapweed Centaurea nigra Common mouse-ear Cerastium fontanum Stemless thistle Cirsium acaule Field bindweed Convolvulus arvensis Smooth hawksbeard Crepis capillaris Lady’s bedstraw Galium verum Cut-leaved cranesbill Geranium dissectum Hogweed Heracleum sphondylium Common catsear Hypochaeris radicata Meadow vetchling Lathyrus pratensis Autumnal hawkbit Leontodon autumnalis Rough hawkbit Leontodon hispidus Lesser hawkbit Leontodon saxatile Ox-eye daisy Leucanthemum vulgare Purging flax Linum catharticum Bird’s-foot trefoil Lotus corniculatus Field woodrush Luzula campestris Black medick Medicago lupulina Creeping rest-harrow Ononis repens Mouse-ear hawkweed Pilosella officinale Burnet saxifrage Pimpinella saxifraga Ribwort plantain Plantago lanceolata Hoary plantain Plantago media Creeping cinquefoil Potentilla reptans Cowslip Primula veris Self-heal Prunella vulgaris Creeping buttercup Ranunculus repens Common sorrel Rumex acetosa Curled dock Rumex crispus

27

Salad burnet Sanguisorba minor Common ragwort Senecio jacoabaea Field madder Sherardia arvensis Dandelion Taraxacum vulgare agg Strawberry clover Trifolium fragiferum Red clover Trifolium pratense White clover Trifolium repens Germander speedwell Veronica chamaedrys Slender speedwell Veronica filiformis Thyme-leaved speedwell Veronica serpylifolia Mosses Brachythecium rutabulum Calliergonella cuspidata Rhytidiadelphus squarrosus

28

APPENDIX 3: NVC RESULTS

1 (north)

1 (south)

2/3/4 (species-

rich)

2/3/4 (species-

poor)

3/4 (rush-dominated)

5 Cemetery (species-

poor)

Cemetery (species-

rich)

Agrostis capillaris

I (4) IV (4-6) III (4-5) II (4) III (2-4)

II (4_ IV (4-6)

Agrostis stolonifera

IV (5-7)

II (3-4) IV (4-5) V (2-6) III (2-4)

IV (2-5) II (4)

Alopecurus pratensis

II (4) II (3) II (4)

Anthoxanthum odoratum

II (3-4) IV (4-5) III (5-6) III (5) IV (3-5)

Arrhenatherum elatius

I (4) I (4) I (6)

Briza media II (4-5)

Bromopsis erecta

III (4-6) III (4-5)

Bromus racemosus

I (4)

Cynosurus cristatus

II (4-5) IV (4-7) IV (4-5) II (4) IV (4-5)

Dactylis glomerata

II (4) I (2) II (1-2) I (4) II (2)

Festuca rubra II (5) III (4-5) III (4-5) III (2-4) III (4)

V (1-6) V (4-7)

Holcus lanatus II (4) III (4-5) IV (3-6) V (4-7) IV (4-5_

II (4)

Hordeum secalinum

I (4) 11 (4-5)

III (4) I (4)

Lolium perenne

V (7-9)

III (5-8)

III (4-6) V (4-7) III (4-6) II (4-6)

V (6-8) V (2-7)

Poa pratensis II (4) I (4) III (4)

Poa trivialis III (4-5)

III (4-5)

II (4) I (5)

II (4-5)

Tristetum flavescens

III (4) II (2-4)

Achillea millefolium

I (4) III (5) II (4-5) I (4) III (4-5)

Agrimonia eupatoria

II (4)

29

1 (north

)

1 (south

)

2/3/4 (species

-rich)

2/3/4 (species-poor)

3/4 (rush-dominated

)

5 Cemetery

(species-poor)

Cemetery

(species-rich)

Bellis perennis I (5) I (3) II (2-4) II (2-4)

Capsella bursa-pastoris

II (5) I (3)

Carex flacca II (2-4) I (4) II (4)

Carex hirta I (4)

Centaurea nigra

III (2-4)

III (2-5) III (4-5)

I (2)

Cerastium fontanum

I (3) III (3) I (2) II (2) IV (2-3)

Cirsium arvense

I (3) I (4)

Cirsium palustre

I (1) I (4) I (1) II (1-4)

Cirsium vulgare

I (4)

Convolvulus arvensis

II (2) I (4)

Galium verum I (4) II (2-4)

Geranium dissectum

II (3-4) I (2)

Hypochaeris radicata

II (3) II (3-4) III (4) I (4) II (2)

Juncus inflexus

V (6-7)

Lathyrus nissolia

I (2)

Lathyrus pratensis

II (2-4) II (2-4) II (4) I (4) I (2)

Leontodon autumnalis

I (1)

Leontodon saxatile

II (4) I (2)

II (2-4)

Leucanthemum vulgare

I (4) III (2-4)

III (4-5) I (5) II (4-5)

I (2)

Linum catharticum

II (3)

Lotus corniculatus

III (2-5)

IV (3-5) III (2-4) I (4) III (4-6)

III (4-5)

Luzula campestris

II (4) I (4)

Odontites verna

II (2-4)

Ononis repens I (5) I (2)

Pimpinella saxifraga

I (3)

30

1 (north)

1 (south)

2/3/4 (species-

rich)

2/3/4 (species-

poor)

3/4 (rush-dominated)

5 Cemetery (species-

poor)

Cemetery (species-

rich)

Plantago lanceolata

III (4) V (2-5) IV (2-4) II (2-4) III (2-4) IV (4-6)

Plantago major

I (2) I (1)

Potentilla reptans

I (4) II (4-5) II (4) II (4) III (4)

Primula veris II (2-4)

Prunella vulgaris

I (4) I (2)

Pulicaria dysenterica

II (4)

Ranunculus acris

III (1-4)

II (2) II (3) I (4) III (4-5)

Ranunculus bulbosus

I (3) I (3) III (4-5) II (4)

Ranunculus repens

IV (2-4)

IV (2-5)

III (3-4) IV (3-5) IV (4-5) IV (2-5)

IV (4-5) III (4-5)

Rumex acetosa

III (4) I (4) I (4)

Rumex crispus

I (1) I (2)

Senecio erucifolius

II (2-4)

Senecio jacobaea

I (1) I (2) II (2-5)

Taraxacum vulgare agg

I (4) I (2)

IV (2-4) III (2-4)

Trifolium dubium

I (2) I (3)

Trifolium fragiferum

I (4) III (5-6)

Trifolium pratense

I (4) III (2-4) II (4) I (2) III (2-4)

Trifolium repens

I (4) I (4) III (4-6) II (4) II (4)

IV (2-6) III (4)

Calliergonella cuspidata

III (2-4)

IV (4) III (4) III (4) V (4) I (3)

31

APPENDIX 4: INSECT SPECIES RECORDED IN FIELDS (TO WEST OF CEMETERY)

Field Number

1 2 3 4 5

Butterflies

Meadow Brown x x x x x

Common Blue x x x

Small Copper x

Marbled White x x x x

Large Skipper x x x

Moths

Burnet Companion x

Cinnabar x

Six-spot Burnet x

Yellow Shell x

Agriphila tristella x x

Crambus perlella x

Chrysoteuchia culmella x x x x x

Grapholita compositella x

Beetles

Cantharis nigra x x

Oedemera nobilis x x x x x

Oedemera lurida x

Coccinella septempunctata x x x x

Bugs

Coreus marginatus x

Bees

Halictus rubincundus x

Bombus terrestris x x x x

Bombus pascuorum x x

Bombus lapidarius x x

Flies

Cheilosia albitarsus x x

Chloromyia formosa x

Chrysotoxum bicinctum x

Lepidogaster cylindrica x

Sphaerophoria scripta x x x

Orthoptera

Meadow Grasshopper x x x x

Roesel’s Bush-cricket x x x x Short-winged Conehead x

32

APPENDIX 5: PLANT SPECIES RECORDED IN FIELD 6

6a 6b

NVC NVC Notes

Grasses

Agrostis capillaris Common bent O IV (2-4)

Agrostis stolonifera Creeping bent R I (2)

Alopecurus pratensis Meadow foxtail R

Anthoxanthum odoratum Sweet vernal grass O IV (4)

O IV (4-5)

Briza media Quaking grass R RLF I (5) GI

Bromopsis erecta Upright brome O III (4-5) GI

Cynosurus cristatus Crested dogstail O III (4)

F V (5-6)

Dactylis glomerata Cocksfoot R

Festuca rubra Red fescue R II (2-4)

O IV (4-5)

Holcus lanatus Yorkshire fog R II (4) R

Hordeum secalinum Meadow barley R R GI

Lolium perenne Perennial rye-grass O IV (2-5)

R II (4)

Phleum bertolonii Small cat’s-tail (R) GI, AN Phleum pratense Timothy R R

Poa pratensis Smooth meadow-grass R

Schedonorus pratensis Meadow fescue R GI

Tristetum flavescens Golden oat-grass R I (3) GI

Herbs

Achillea millefolium Yarrow R O III (4)

Agrimonia eupatoria Agrimony R OLF II (4-5) GI

Ajuga reptans Bugle R

Bellis perennis Common daisy R I (4)

Carex caryophyllea Spring sedge R I (2) GI

Carex flacca Glaucous sedge R R GI

Carex hirta Hairy sedge R

Centaurea nigra Black knapweed R O III (2-5) GI

Cerastium fontanum Common mouse-ear R R

Cirsium arvense Creeping thistle R

Cirsium palustre Marsh thistle R R

Cirsium vulgare Spear thistle R

Convolvulus arvensis Field bindweed R

Galium verum Lady’s bedstraw RLF II (4) GI Heracleum sphondylium Hogweed R

Hypochaeris radicata Common catsear O III (4)

O III (4)

Juncus effusus Soft rush R

Juncus inflexus Hard rush RLF I (5)

Lathyrus pratensis Meadow vetchling R O III (2-4) GI

Leontodon saxatile Lesser hawkbit R R I (4) GI

Leucanthemum vulgare Ox-eye daisy R I (4) O III (2-5) GI

Linum catharticum Purging flax RLF II (3) GI

Lotus corniculatus Bird’s-foot trefoil O II (2-5)

OLF IV (5-6) GI

Luzula campestris Field woodrush R GI

Lysimachia nummularia Creeping jenny (R) GI

Oenanthe pimpinelloides Corky-fruited water dropwort R GI, AN

Ononis repens Creeping restharrow RLF I (5) GI

33

6a 6b Notes

NVC NVC

Plantago lanceolata Ribwort plantain O III (2-5)

O IV (4-6)

Potentilla reptans Creeping cinquefoil R R

Primula veris Cowslip O III (2-4) GI

Prunella vulgaris Self-heal R R

Ranunculus acris Meadow buttercup R O II (4)

Ranunculus bulbosus Bulbous buttercup R

Ranunculus repens Creeping buttercup O IV (2-6)

R II (4)

Rumex acetosa Common sorrel O III (2-4) GI

Senecio erucifolius Hoary ragwort R GI

Senecio jacobaea Common ragwort R

Succisa pratensis Devil’s-bit scabious RLF I (5) GI Taraxacum vulgare agg Dandelion R II (2)

Trifolium dubium Lesser trefoil R I (2) R

Trifolium fragiferum Strawberry clover O II (4) R I (2) GI, AN

Trifolium pratense Red clover O III (4)

R I (2)

Trifolium repens White clover R III (2-4)

R I (2)

Veronica serpylifolia Thyme-leaved speedwell R

Vicia cracca Tufted vetch R GI

Mosses

Calliergonella cuspidata O III (3)

O IV (2-3)

Kindbergia praelonga R I (2)

Pseudoscleropodium purum RLF I (3) GI

Rhytidiadelphus squarrosus OLF III (3-4) GI

Abundance codes: D – dominant; A – abundant; F – frequent; O – occasional: R – rare; L – locally. Notes: GI – grassland indicator species; AN – Avon Notable Species.

34

Hi,

I am writing to object to the expansion of the crematorium by taking away land that has beenused by Yew Tree Farm, Bristol’s last working farm. Yew Tree Farm, designated as aSNCI, operates traditional farming practices and as such is vitally important for nature, whichhas such a positive impact on biodiversity and therefore contributes to reducing climate change,which is surely a target for Bristol council. However urgent you may argue it is to allocate landfor a crematorium, please do not use land which has been identified as a cite of natureconservation.

I therefore strongly object to the expansion of the crematorium on the grounds that it willnegatively impact on land which has been designated as a SNCI. I object to it morally, ethically,and legally.

Dear Planning Committee

I object to the above planning application for several reasons:

I understand this farm is in the green belt and should not be developed for a cemetery.

The site is a SNCI and should not be developed according to policy DM19. Passing thisapplication would violate the Green Space motion passed by BCC in September 2021. Thismotion states that green belt and SNCI should be protected. You will be voting against your ownmotion.

I understand that the development will undermine to the point of death veteran trees

Yew Tree farm will suffer as a result and may go out of business.

This is a well loved local site for recreation for Bristol residents and its loss will be deeply felt.

Sites like these are under threat and development as per this application will only exacerbate ourclimate and ecological emergency.

I understand no other sites have been considered for use as a cemetery.

Hello,No amount of replanting and landscaping can compensate for the unnecessary removal ofcenturies old natural flora and fauna.It is damage however you dress it up.Please honour the intentions of this city (and council) in protecting all the land that Yew tree Farmexists upon.I suggest using sections of Ashton Court for a new burial ground and to fully explore other options.Please leave Yew Tree Farm alone.You can declare your decision to not touch the farmland and make yourself look good and in tunewith the majority.Kind RegardsAlec

I am writing to object to the expansion of the crematorium by taking away land that hasbeen used by Yew Tree Farm, Bristol's last working farm. Yew Tree Farm, designatedas a SNCI, operates traditional farming practices and as such is vitally important fornature, which has such a positive impact on biodiversity and therefore contributes toreducing climate change, which is surely a target for Bristol council. However urgentyou may argue it is to allocate land for a crematorium, please do not use land which hasbeen identified as a site of nature conservation.

I therefore strongly object to the expansion of the crematorium on the grounds that it willnegatively impact on land which has been designated as a SNCI. I object to it morally,ethically, and legally.

A very concerned citizen

I am writing to object to the expansion of the crematorium by taking away land that hasbeen used by Yew Tree Farm, Bristol's last working farm. Yew Tree Farm, designatedas a SNCI, operates traditional farming practices and as such is vitally important fornature, which has such a positive impact on biodiversity and therefore contributes toreducing climate change, which is surely a target for Bristol council. However urgentyou may argue it is to allocate land for a crematorium, please do not use land which hasbeen identified as a cite of nature conservation.

I therefore strongly object to the expansion of the crematorium on the grounds that it willnegatively impact on land which has been designated as a SNCI. I object to it morally,ethically, and legally.

All LPA's face difficult choices in balancing policy, public need andsocietal/environmental benefits and this application is a case in point.

I urge the Council to find an alternative to expanding cemetery provision into this unique site, oneof a vanishing number of SNCIs and also of course home to the last working farm in Bristol. Iunderstand the need, but am unpersuaded by the documents relating to mitigation measures -what is proposed is quite simply the destruction of a precious and biodiverse resource. The plan ismisconceived and misguided. Alternatives have not been evaluated. The benefits are massivelyoutweighed by the harm that would be caused.

Development Control Committee B has - in distinct contrast to its fellow Committee A - areputation for careful evidence based consideration and respect for the views of both localresidents and all those who care enough to express their views. Please reject this application.

Thank you.

Yew tree farm land has value far beyond just land. As a SNCI and it's work furtheringour sustainability understanding it should be protected.

Wholeheartedly object to such a proposal as again,it will damage theenvironment,reduce biodiversity and to lose the farm will be a massive massive loss for the futureof Bristol.

Hi,I am writing to object to the expansion of the crematorium by taking away land that hasbeen used by Yew Tree Farm, Bristol's last working farm. Yew Tree Farm, designatedas a SNCI, operates traditional farming practices and as such is vitally important fornature, which has such a positive impact on biodiversity and therefore contributes toreducing climate change, which is surely a target for Bristol council. However urgentyou may argue it is to allocate land for a crematorium, please do not use land which hasbeen identified as a cite of nature conservation.I therefore strongly object to the expansion of the crematorium on the grounds that it willnegatively impact on land which has been designated as a SNCI. I object to it morally,ethically, and legally.A very concerned citizen,

Dear Members of the Planning Committee,

I am writing to express my enthusiastic support for the proposed expansion of SouthBristol Cemetery, and I would like to share my perspective as a memorial mason whosebusiness is likely to obviously benefit from this development.

However, it should be also appreciated that not only our business but also ouremployees, along with the feedback we have received from our clients and the widerbereaved community, strongly support this expansion as it plays a crucial role inproviding an essential service to both the local community and the city as a whole.

1/ Bereaved Community Feedback:

We have consistently received feedback from our clients and the wider bereavedcommunity about the pressing need for more burial space in our city. Families often findthemselves struggling to secure plots and spaces for memorialization, causingadditional stress during an already challenging time. The expansion of South BristolCemetery will address these concerns and provide relief to grieving families, allowingthem to properly honour their loved ones.

2/ Essential Service for the Community:

Cemeteries are not merely places for burial; they are vital to our community's collectivememory and cultural identity. A cemetery provides a lasting place of remembrance,solace, and reflection. The expansion of South Bristol Cemetery will continue to serve

as an essential facility for residents, ensuring that future generations have access to adignified and respectful place to remember their ancestors.

3/ Employment Opportunities and Employee Welfare:

Expanding South Bristol Cemetery will not only benefit business owners but alsoemployees within our industry. It will create new job opportunities, including masons,landscapers, maintenance staff, and administrative roles. Moreover, the expansion willlikely lead to a sustained demand for skilled craftsmen and women, ensuring jobsecurity and professional development for our workforce. These opportunities are notonly economically advantageous but also contribute to the overall well-being of ouremployees and their families.

4/ Business Benefits:

As a memorial mason, I understand the profound impact that the cemetery expansionwill have on our industry. With limited space in existing cemeteries, it has becomeincreasingly challenging for families to find suitable resting places for their loved ones.This expansion will alleviate the pressure and provide more opportunities for memorialservices, gravestones, and other memorial products. Consequently, this will fostergrowth and stability for memorial businesses like mine, ensuring we can continueserving the community effectively.

In conclusion:

I urge the Planning Committee to give serious consideration to the expansion of SouthBristol Cemetery. This project promises numerous benefits for the memorial masonryindustry, its employees, our clients, and the bereaved community at large. Furthermore,it upholds the essential role cemeteries play in our society, offering solace, continuity,and a lasting connection to our history.

I trust that the Planning Committee will make the right decision in the best interest of thecommunity and the city as a whole. Your support for this expansion will undoubtedlyhave a positive and lasting impact on our community.

Thank you for your time and consideration.

Yours sincerely,

We must not allow Bristol's last working farm to be effectively dismantled, in anirreversible decision that does not represent the views of local people in what should be a localdecision.

I object to this loss of land to the last working farm in Bristol

Please leave it as is.

It is a vital area for conservation and nature rich landscape to work in hand with the farmthat has been it's custodian for so long. It is the last working farm in Bristol why do wish to diminishthat more. Green spaces are few and far between and this area is a jewel in the crown of the area.Serious objection

I have visited Yew Tree Farm on several occasions. It is a wonderful and unique cornerof Bristol. I was very impressed by how it is managed on the edge of the city. The Farm needs allthe land it has to be viable including the hay meadow.The expansion of the cemetery would be very harmful to the farm's future. Another site needs tobe found instead. Please do not extend the cemetery into the Farm.

From everything I've read about this, I just can't believe that anybody thinks it's a goodidea. If ever there was a time when we need quality garland, it's now! Please reconsider and savethe farm!

I am a horticulturalist specializing in food production and ecology. I have been workingat Yew Tree part time since returning to work after starting a family in March of thisyear. I have been looking after the vegetable garden which supplies the farm shop andwe hope to be able to expand the operation next year.

The farm is a fantastic example of a low impact food producer working in harmony withnature and has an abundance of native tree, wild flower, insect and bird species whichare apparent as soon as you step onto the pasture.

The particular site in question, complete with ancient oak, maple and tri-trunked crab,is enjoyed by a daily procession of local walkers as well as the swifts swallows and jayswhich hunt there.

Not only would all this be gone, but if the loss of the land renders the farmeconomically non-viable I would lose my job, locals would lose an excellent source offresh produce, and the charitable groups who bring their clients there to experiencerural activities would have to find somewhere else, and there are not many places likethis still going in the region.

The proposal to take fertile land out of food production and instead to use it for burials,which are unnecessary, is a bizarre decision for a country already struggling to feeditself. I hope this folly will be reconsidered, and you might try building up the level ofexisting sites as other councils are doing, and allow cremation only within thejurisdiction.

Thank you for your time,

QUESTION DID YOU NOT ANNOUNCE YOUR COMMITMENT TO NARURERECOVERY.So was that just smoke screen fir popukarust PC statements because djnce then you have dkneNITHJNG TK BACK UO THESES STATEMENTS . EX HAVE JUST RECENTLY PASSEFMD APLANNJNG DECUSIKB TO DEREGUKATE ALL REMAJNING SNCI's hardly jn favour ofcommitment to nature more to the building industry and rhus havjng sold ouf Brusljngton Meadowsin shsmeful lies to its local population promising af ekection tjme it wiukd be safe. So now you gofir thd kast remaining WIRKING farm

QUESTION .DID YOU NOT ANNOUNCE YOUR COMMITMENT TO NATURERECOVERY.So was that just smoke screen for popularist PC statements because since then you have doneNOTHING TO BACK UP THESE STATEMENTS . Infact quite the opposite EG HAVE JUSTRECENTLY PASSED A PLANNING DECISION TO DEREGULATE ALL REMAINING SNCI's, sohardly in favour of your commitment to nature more to the building industry and this having soldout Brislington Meadows in shameful lies to its local population promising at election time it wouldbe safe. So now you go for thd last remaining WORKING farm in Bristol for a crematorium thatcould indeed SHOULD be built on brown field sites in the area especially as in one of the fields anentirely NEW SPECIES OF INSECT HAS BEEN DISCOVERED. SO PROVE YOURCOMMITMENT TO NATURE AND SAVE THIS SPACE AS POSSIBLY THE ONLY HOME TOTHIS NEW SPECIES AS A PRIME EXAMPLE OF YOUR STATEMENT THAT YOU CANPUBLICALLY DECLARE AND BE HEREALDED FOR

QUESTION. DID YOU NOT ANNOUNCE YOUR COMMITMENT TO NATURERECOVERY.So was that just a smoke screen popularist PC statement, because since then you have doneNOTHING TO BACK UP THIS STATEMENT infact the exact opposite . EG HAVE JUSTRECENTLY PASSED A PLANNING DECISION TO IGNORE THE STATUS OF ALL THIS CITIESREMAINING SNCI's, hardly in favour of a commitment to nature, more to the building industry andthis having sold out Brislington Meadows in a shameful lie to its local population promising atelection time it would be safe. So now you go for the last remaining WORKING farm in Bristol for acrematorium that should be built on a local brownfield site, also a policy statement of this council.So prove your commitment to nature and save this very unique & special place especially as veryrecently an entirely new species of insect had been discovered and this site maybe the only site ofexistance for this new species.So do you want to be responsible for its destruction or use theopportunity to very publically declare its saving as a example of your commitment to nature andthe huge acclaim you will recieve for it

I am writing to register my incredulity and anger at the Council's desire to build houseson Yew Tree farmland and to extend the crematorium onto its land.

In 2020 you announced an Ecological Emergency and pledged to put nature at theheart of decision making. How on earth can wrecking this ecologically diverse, beautifuland important land be in any way part of that? You need to have the courage to standfirm by your commitments and not renege on them like this pathetic NationalGovernment has recently done. There is undoubted climate change happening globallyand we all have to play our part; building on this land would be an appalling act ofirresponsibility.

It is land designated an SNCI and is in the Greenbelt (like Longmoor Field is and youalso seem wilfully to be ignoring that fact there too) so treat it with the respect andimportance it deserves, preserving and valuing its habitat for our own and futuregenerations.

I support the SNCI status of Tew tree farm and it is a very important for Bristol Southand Bristol as a whole for having a wildlife friendly local farm with public footpaths is forBristol. This is important for wildlife, well being, and health. We should mot loose thisfarm it is part of our history of South Bristol.

I strongly object to this development. No other sites were considerrd and instead thecouncil have decided they can decicrate a SNCI. This designation should protect the site from anyhuman development by recognising the habitats and wildlife that have taken half a century todevelop there. Look elsewhere, this will be destruction, not development.

2

information:

• Site 1a – 526 double and 373 single burials.

• Site 1b will be used exclusively for ash interment.1

• Site 3 – 1,981 double burials.2

This makes a total of 5,387 burials in 2,880 plots in the proposed extension. On this basis,

we are told, Site 1a and phase 1 of Site 3 will not reach capacity until sometime between

2034 and 2039. Phase 2 of Site 3 will then be developed and brought into service. I calculate

that this will provide 1,206 burial plots.3

This assumption is based on the majority of graves (2,507) being suitable for double burials.

However, the evidence provided does not support this assumption, as the shallow soil depth

indicates that most, if not all, will be single burials.

The Tier 2 groundwater risk assessments

Two Tier 2 groundwater risk assessments dated September 2018 were prepared by Cemetery

Development Services. Both have been submitted as part of the application:

1. 22_05714_FB-GROUNDWATER_RISK_ASSESSMENT_BRISTOL_CITY_COUNCIL-3351171

2. GROUND_WATER_RISK_ASSESSMENT-3351196

These reports advise that only single-depth burials should take place (highlighted below):

It appears that there is no updated report suggesting that the double-depth burial plots

proposed are viable.

Both reports, which assumed that there would be 227 burials per annum, also conclude that

‘The site is considered to be high risk, with the risk mainly attributed to the predicted burial

numbers.’ This issue has not been addressed and remains a contraindication for this site.

The Tier 3 groundwater risk assessments

Tier 3 risk assessments of Sites 1 & 3 were prepared by Hydrogeo in July 2021.4 These

concluded that:

1 22_05714_FB-DESIGN_AND_ACCESS_STATEMENT-3351161 2 22_05714_FB-D200012-CDS-EN-ZZ-DR-L-009L_AREA_3_-_LANDSCAPE_PLAN-3398609 – see the Legend. 3 On the basis that phase 2 covers nearly 61% of the Site 3 area. 4 22_05714_FB-SITE_1_TIER_3_GROUNDWATER_RISK_ASSESSMENT-3351167 and 22_05714_FB-SITE_3_TIER_3_GROUNDWATER_RISK_ASSESSMENT-3351168

3

Based on the results of the quantitative hydrogeological risk assessment the

proposed cemetery extension at South Bristol Cemetery is unlikely to result in

adverse impacts to water quality when reaching the identified receptor; with

concentrations of ammonia modelled to be below background concentrations

recorded in local surface waters.

However, this was based on the assumption that all surface water being drained from the

existing burial ground in the north of the cemetery and from Site 1 would first enter the

proposed attenuation pond:

The CDS drainage proposal is for a series of 70mm drains running along the

pathways between burial plots (above the internment level) directing surface and

perched water to the north to be collected by larger (100-150mm) drains. The

collected water will be directed towards the north or north-west where it will be

accepted by a 375mm pipe that runs along the Site 1 northern boundary. This

water is then directed to the attenuation pond to be installed approximately

400m to the north.

This is no longer what is proposed. The water will now be discharged directly into Colliter’s

Brook, and therefore the conclusion that there will be no adverse impacts on water quality

are no longer valid. As such, the groundwater risk assessments must be updated.

The reports also assume that there will be 105 burials/year for ten years. However, the

council is working on the basis that there will be ‘around 300 burials/year and around 200

new graves, including cremated remains plots.’5

No new drainage or hydrological report has been produced which addresses the implications

of these changes.

It is also notable that the Tier 3 assessment for Site 3 was predicated on the site

accommodating 1,050 burials rather than the 1,981 burials now proposed. Site 1 also

assumed 1,050 burials, not the 899 now proposed. The fact that a figure of 1,050 burials is

quoted for each site suggests that this figure may be the combined number for both sites.

I also note that both of the Tier 2 reports advise that ‘... prior to any consent being given

by the Environment Agency, an assessment of risk should be undertaken.’ The Environment

Agency has commented and advised:

This development will require a permit under the Environmental Permitting

(England and Wales) Regulations 2016. Further guidance can be found at

https://www.gov.uk/government/collections/risk-assessments-for-specific-

activitiesenvironmental-permits. Where a developer decides not to parallel track

their planning and environmental permit applications, we will not offer detailed

advice or comments about how permitting issues affects planning.6

It appears that the Council has decided not to ‘parallel track their planning and

environmental permit applications’. This represents a risk, as it is not certain that such a

retrospective environmental permit application will be successful.

I also note that the Council’s own consultee dealing with Contaminated Land Environmental

5 https://democracy.bristol.gov.uk/documents/s46673/Appendix%20E%20-%20Redacted%20Signature%20SBCE%20EqIA%20Full%20Form%20Jan20.pdf 6 22_05714_FB-ENVIRONMENT_AGENCY-3372546

4

Protection issues, who seems only to have been consulted at the very last moment, has

criticised a number of aspects of the proposals:

The application has no real details regarding potential reprofiling of land and

suitability of the material on site for this purpose, no details of how materials will

be managed, especially with respect to the attenuation basin excavation etc.

The Groundwater Risk Assessment's do not include any soil tests, the only tests

undertaken were to characterise the water environment so we have no

understanding of soil conditions. No human health risk assessment, particularly for

construction workers and cemetery operatives has taken place. Potentially some of

this was covered by earlier assessments but we have not seen this information.

Given the absence of information available I would be minded to refuse on the

grounds of insufficient information being provided. However given the very late

stage of our team being made aware of the application and the imminent

committee hearing we can recommend conditions. If further information is

available which demonstrates human health risk assessment has been considered

we can review, albeit not before tomorrow's committee.7

No explanation has been given as to why the consultee was consulted only a day before the

Development Control Committee was due to consider this application.

Given the above anomalies, not yet addressed by the applicant, it appears that this

application is not yet ready to be properly considered. In addition, given that the

Environment Agency, as Primary Consultee, is able to prevent any site being developed

should that site be deemed to represent too great a risk in respect to groundwater pollution,

I suggest that the Agency should be involved in advance of the application being considered

by the Development Committee.

Burial capacity

Different figures for the annual need for burials have been provided.

When Cabinet met in March 20208 it was advised that ‘...the rate of burials as 227 per year

(based on 2016/17 figuers [sic]) ...’. Another paper produced at the time advised: ‘... South

Bristol is the busiest site in the City dealing with around 300 burials a year and around 200

new graves including cremated remains plots.’9

The Tier 2 reports referred to above assumed 227 burials per annum, while the later Tier 3

reports assumed 105 per annum.

Given that the figures presented to Cabinet in 2020 were already three to four years out of

date at the time and given the subsequent COVID pandemic and the evidence of increased

post-COVID death rates - year-to-date (January to April 2023) deaths were above average in

England (7.2% above average)10, I suggest that these figures underestimate current burial

7 22_05714_FB-CONTAMINATED_LAND_ENVIRONMENTAL_PROTECTION-3525798 8 https://democracy.bristol.gov.uk/documents/s46623/Appendix%20A%20-%20The%20Future%20of%20Bristols%20Cemetery%20and%20Crematorium%20provision%20v.5.pdf 9 https://democracy.bristol.gov.uk/documents/s46673/Appendix%20E%20-%20Redacted%20Signature%20SBCE%20EqIA%20Full%20Form%20Jan20.pdf 10 https://www.ons.gov.uk/peoplepopulationandcommunity/birthsdeathsandmarriages/deaths/bulletins/monthlymortalityanalysisenglandandwales/april2023#:~:text=Accounting%20for%20the%20population%20size,%25%20below%20average%2C%20respectively

5

rates by a significant margin. The Council should provide updated figures in advance of any

application being considered.

For the time being, I have adopted the upper limit proposed – 300 p.a. – and produced the

table below showing how long the proposed burial provision is likely to last. I have assumed

that only single-depth burials are possible on each site, given the Council’s own evidence

discussed above.

Burial Provision Total No. Years

of Supply

Year site

full

Site 1a 373 Single

899 3.0

526 Single

Site 3 - Phase 1 775 Single 775 2.6

Sub-total 1,674 5.6 2029

Site 3 - Phase 2 1,206 Single 1,206 4.0

Total 2,880

2,880 9.6 2033

Burial Rate – 300 per

annum

On this basis, phase 1 will reach capacity in 2029 with the post-phase 2 provision filling up

by 2033, just ten years from now. As such, this is not the long-term solution to Bristol’s

need for additional burial capacity, and therefore the benefits do not outweigh the clear

detrimental impacts of this proposal.

It's about time that development of green areas is stopped. Especially in an area ofSNCI which should be protected at all costs.

I understand the need for burial grounds but I think this is a wrong. Yew tree farm is likeBristols own mini-Knepp ( rewilding estate in Surrey ). With the UK's nature crises and globalclimate crisis now is not the time to be lowering biodiversity which weakens our environmentalsystems that we need to be sting now more than ever. I have walked the rough Yew Farm and amamazed at the amount of wildlife it has there. This needs to be protected and become anotherasset to Bristol and something we can all be proud of. Finally a macabre comment. With ourclimate at threat - destroying this nature, species rich habitat to bury people - seemscounterintuitive on a number of levels. Are there alternate sites that can be looked into?

Yew Tree Farm should be allowed to continue as Bristol's last working farm without thethreat of the expansion of the cemetery and housing. This site which is an SNCI is so important fornature and wildlife. What is the point declaring an ecological emergency if sites like this are notprotected? Please let's have some joined up thinking!

There seems to be a coordinated attack on the last working farm in Bristol...This site is so important and the Council have not looked at any other viable sites for a cemetery.

Yew Tree Farm is an SNCI and must be protected from development. It is also a vitalspace for biodiversity and a haven for wildlife which should be encouraged not removed from thecity.

Leave the farm as it is.

Having grown up in Bristol and witnessed the strides and incredible progression ofenvironmentalism that the city has made, it makes me incredibly proud to say I am from thisregion. This would be a devastating blow not only to local wildlife but also communities that needthese spaces more then ever. It would also be another nail in the coffin for the plight of our planet.This distressing trend in local and national government to turn a blind eye and pretend that theclimate crisis isn't happening is disgusting. We need to do all we can to safeguard these heavensfor wildlife now more then ever. Take action.

Commentary of the loss of Yew Tree Farm pasture 11 September 2023

2

The Council-owned land farmed by Yew Tree Farm, whose boundary is outlined in red, covers

an area of 10.5 hectares3.

We have superimposed the site of the proposed new Site 3 burial ground (phase 1 is coloured

yellow and phase 2 is coloured purple) and the attenuation pond (coloured blue). The yellow

lines show the approximate courses of the main proposed buried drains.

The direction of flow of the drainage is from the existing and proposed burial grounds to the

east and south down to Colliter’s Brook on the western Boundary of the farm. The drainage

installed by Railtrack is from east to west beside the railway track. There is no attenuation

pond for this.

We also show, in grey, an area to the south of Site 3 (the Top Field) which will become

inaccessible to the farm when the Site 3 fencing is erected. Quite apart from curtailing the

farm’s access to this pasture, it will also jeopardise the long-term nature conservation value of

this land as part of the SNCI if cattle no longer have access to it.

Here is a breakdown of the size of each of these areas:

Feature Area

(ha)

% of BCC

Land

Attenuation Basin 0.6 5.6%

Site 3 Burial Ground 0.8 7.9%

Top Field 1.5 14.1%

Total 2.9 27.6%

BCC-owned Land 10.5

On this basis, Yew Tree Farm will lose access to nearly 28% of the Council’s land which it

currently farms. If this is not accepted, we invite the Council to set out the basis of its own

calculation together with a map showing the Council-owned land.

In addition, the proposed position of the attenuation pond, at the bottom of the field, means

that there is likely to be only very restricted access to the pasture above it, given the proximity

of the nearby hedgerows, the pinch-point to the west and along the Public Right of Way (PROW)

to the north. Cows are known to follow established routes when moving between pasture. This

can result in these paths becoming very muddy which would make it difficult for walkers using

the PROW, especially in winter or when it is wet.

3 Approximately 104,688 sq metres. 1 hectare = 10,000 sq metres.

Commentary of the loss of Yew Tree Farm pasture 11 September 2023

3

We have raised this issue and the issue about the inaccessible pasture (coloured grey) to the

south of Site 3 but have not had any response.

We also believe that, in addition to these issues, the following issues must be addressed before

the Council’s application is considered again by the Development Control Committee:

1. How will spoil from the excavation of the attenuation pond and drainage excavations be

disposed of?

2. How will the installation of the proposed drainage and fencing be phased?

3. Construction Management and Transport Management Plans dealing with the methodology

to be used to install the burial grounds, the attenuation pond and the associated drainage

and to ensure that site access is managed in the way that will minimise damage to the SNCI

needs to be produced.

4. What methodology will be used to install the drainage?

5. How will any damage caused by construction be made good in order restore the site, in

particular the SNCI, to its baseline state?

6. A methodology for working within the roots of trees and hedgerows needs to be produced.

7. A Landscape Ecological Management Plan (LEMP), which addresses the above points and

sets out a long-term management plan which will secure the future of the Colliter’s Brook

SNCI, should be produced.

8. A proposal to secure the ring-fenced funds required for discharging the LEMP obligations is

required.

9. The extent of the pasture land the Council proposes leasing to Yew Tree Farm must be

identified and the lease agreed.

In the meantime, this application should not be brought back for a decision until all the

documents which the Council intends to rely on in support of its application have been

published,4 in good time, for the proper consideration of stakeholders.

4 The word published means to make available to the public.

Commentary of the loss of Yew Tree Farm pasture 11 September 2023

4

Annex – Councillor Ellie King email dated 5 August 2023

From: Councillor Ellie King

Date: Sat, 5 Aug 2023 at 20:17

Subject: RE: Yew Tree Farm and Crematorium. Not either/or

To: Maddy Longhurst, Councillor Ed Plowden, Councillor Andrew Varney, Councillor Farah

Hussain, Councillor Tom Hathway, Councillor John Geater, Councillor Richard Eddy, Councillor

Fi Hance, Councillor Christopher Jackson, Councillor Philippa Hulme, Democratic Services

Cc: Councillor Nicola Beech, Councillor Asher Craig, Louise Delmege, Leon Ballin, Heloise

Balme, Gillian Morgan

Hi Maddy,

Thank you for your email and for your advocacy. As you’ll be aware, the decision to develop

the site sits with a cross party development committee (cc’d for awareness) that will be

meeting on Wednesday 9th August to determine the outcome of the application.

However, after careful consideration I have formed a view based on briefings and discussions

with officers on the proposals. It is a nuanced one. As you and others on this circulation know

sustainable and healthy food is extremely important to me, but I don’t believe this

development signals the end of Yew Tree Farms ability to operate, on the contrary I think it

will help ensure their future.

The context: When the farm entered in to an informal agreement a few years ago to

temporarily graze on the land, they knew from the outset that it was intended for the

cemetery expansion. It would be disingenuous to suggest otherwise. This is Bristol City

Council land and we have an obligation to provide burial space for Bristol residents. Almost all

of our sites are at capacity. There is no other alternative site, and this would be a significant

equalities issue if we were to not expand the cemetery to accommodate need. The decision

reached by the committee needs to balance the benefits to the whole of Bristol with the

concerns voiced by Yew Tree Farm and others.

The first phase of development is to take 10-15 years, and will utilise just 4% of the current

grazing land. I have been advised that this is equivalent to the grazing land for just 1 cow and

1 calf. As the development will be done slowly over a number of years, the farm will have

adequate time to adjust and adapt.

In depth, sound ecological reports have indicated that the SNCI status of the site has not been

managed suitably and there has been a reported decline in the ecological value of the

grassland within the SNCI in the past 20 years. This is in part due to the encroachment of

scrub which has not been actively managed.

The proposed development is subject to implementing a 30 year Landscape and Ecological

Management Plan (LEMP) to halt the decline through grassland restoration and ensure the site

contributes to biodiversity Net Gain (BNG) and the SNCI status is maintained as such. This

would be an explicit condition upon approval of the proposal. The wildflower meadow isn’t in

scope and the hedgerow and tree planting will be increased as well as protection put in place

for the current ancient hedgerow.

Commentary of the loss of Yew Tree Farm pasture 11 September 2023

5

On to the Farm’s future. The council cannot enter into a long term lease with Yew Tree Farm

until it is able to develop a long term management strategy for the site. But the development

of this management plan is subject to getting this planning application approved. A chicken

and egg situation that indicates it is in the best interests of the future of the farm to get this

planning decision approved, so that we can work together to get a lease for the farm with the

required management provisions which will give them long term security and resilience. I am

very keen to support the farm with this.

Yew Tree Farm is a valuable asset, but we have to consider the status of the SNCI, the need

for burial space and weigh that up with what is only 4% loss of grazing land (approx the space

for 1 cow-calf pair) over the next 10 – 15 years. Ideally we could do all these things but this is

frequently an occupational hazard of working in a city with finite space, resource and

competing priorities.

Thanks again for your email, I hope you receive this response in the collegial nature it is

intended. This is my view, but the decision rests with the committee.

Thanks,

Ellie

Cllr Ellie King

Labour Councillor for Hillfields

Cabinet member for Public Health and Communities

Dear Sir/Madam

I am writing to express my concern with regards to the expansion of the crematoriumand the resulting loss of land used by Yew Tree Farm.This is absolutely not what we should be doing if we are to protect our world from theimpact of climate change.I beg you to re-evaluate this proposal and for the sake of future generations do what isbest for our precious world .

Yours sincerely

For the attention of the committee

22/05714/FB

I am a Bedminster Down resident and strongly object to the application above.

Yew Tree Farm is the last remaining farm in Bristol. Not only that, it is an absolutetreasure trove of pollinators, birds and other wildlife. I have spent many a happyafternoon on the farm photographing the butterflies and birds, as it beats Ashton Courtand many AWT sites for its flourishing wildlife. This year alone, 15 swallows havefledged from the farm, and they are an absolute joy to watch. It's also the only place inBristol that I can guarantee seeing Painted Lady and Skipper butterflies. The farm alsohas regular visits from a Greater Spotted Woodpecker family, and is home toGoldfinches and Blue and Great Tits, and many other birds.

As I am sure you are aware, the land is an SNCI, so I am appalled that you will evenconsider this application. My understanding is that the land cannot be redevelopedunder policy DM19. Why hasn't this application already been declined?

Why are you proposing development of greenbelt land? In 2021 the Council passed amotion to protect greenbelt sites.

Are you aware that many of the old trees on the site will not survive your plans?

Do you even know there's a climate emergency?!

Suffice to say that I am disgusted that these plans and the application has made it thisfar and I'd like to know what other options have been explored?

To reiterate: I object in the strongest possible terms to this application.

Kind regards

Have Bristol Council considered creating a sustainable farmland burial ground, whichcould continue as a pasture and meadow landscape? Turf is replaced after a burial, graves are notmarked and it is all mapped digitally.

I run Leedam Natural Hertiage and we work with landowners to develop burial grounds across theUK, many of whom are farmers looking to diversify, but continue using the land as productivefarmland. We would be happy to work with Bristol Council and the current occupiers who arefarming the land to develop this site. It will be far cheaper to implement with minimal set-up costsand maintenance costs will be greatly reduced, as it can continue to be farmed.

Traditional cemeteries are a long-term liability and cost for already stretched council budgets andare often not sustainably run (granite headstones from across the world, plastic tributes, non-native flowers wrapped in plastic, constant mowing etc.)

We would be happy to come and discuss this with both parties involved.

I read with interest about the difficult situation at Yew Tree Farm. I think we might beable to help with a regenerative solution...

For the last twenty years, we have been setting up and operating natural burial grounds on activefarmland across the UK. Burials take place on land that continues to be grazed, so there is no lossof farmland. Memorials are not placed on graves; instead, there are grouped memorials atstrategic points where people can gather and read the names and dates of people at rest in themeadows. These points of focus also provide places for new friendships and bonds to be made.

At our burial grounds, every plot is precisely mapped and we provide families with GPScoordinates and What3Words addresses for the graves so they can revisit the spot in the future.These will never change. Infrastructure and tracks are kept to a minimum and are built asvernacular, farm-style tracks with soft edges and porous gravel surfaces. The landscape andheritage of the area are preserved.

For Bristol Council, this would be a departure from the standard cemeteries of the past, and wouldrepresent a regenerative future, where human remains would replenish the earth and the natural,biodiverse green space above would replenish the soul. The burial ground could be incorporatedinto the national nature restoration strategy with a recognition that decomposition is an essentialpart of the nutrient cycle.

What we propose is well-established, tried and tested. The council can visit our nearest naturalburial grounds at Bath and Usk. We would be delighted to provide guided tours and to visit Yew

Tree Farm and talk to everyone involved.

This proposal is low cost, very low impact, environmentally, socially and economically sustainableand would represent a win-win solution. Unlike a standard cemetery extension, it achieves naturerestoration and preservation goals and provides natural green space for the well-being of thecommunity.

I hope that this alternative proposal will be positively received and that we will be able to work withthe council and the farmer to investigate this further.

I write this for my own health and for all of usTogether we have the opportunity to save not merely a piece of land but a way of lifethat makes Bristol special because we care deeply about our land everything yew treefarm as a whole stands for and has brought about as a part of the immediate communitybut so much more far reaching ,

This unique, and sadly the ,last green farm at the edge of south Bristol not onlydeserves saving for their diligence and hard work in providing ethical and nourishingnurturing healing food including honey in keeping with nature which has helped supportmy health personally ( and makes eating nourishing local organic food accessible andaffordable)but their amazing respect and midwifery holistic care of the land is necessarynay vital in preserving and maintaining our green belt.

Aptly named Yew tree farm produce is part of a cycle of life and without the tenderguardianship of the farmers this beautiful space for being with nature and supported byrespectful organic farming practices a prolific wildlife spot would be lost. Let the Yewtree and her farm be celebrated as a place of everlasting life and rebirth in exploringother more positive burial ground options.

Putting the Bee back in Bristol

Thank-you for your time and open minded awareness in acknowledging how we have aduty of care to conserve all of our lives and livelihoods sustainably environmentallyecologically economically working the land with great kindness and respect

the role our land has in our health happiness and heritage in supporting and reaffirmingyew tree farm is a truly Bristolian custodian of our and future generations health .

this our last remaining working farm a treasure on our doorstep that will pay testamentto and remain a stalwart of Bristols movement and realisation as the Green capital

Let’s realise what we’ve got together nowand together we can find a way forward

# green belt . fresh air , trees, bees, nature Joni Mitchell

My daughter received food boxes from Yew Tree Farm all during covid and is part of thehealthy food chain that should be promoted in our city. I want to support their continuedexistence. Looking into the current detail it seems that this is green belt and hasalready been turned down for housing. I suggest that the cemetery looks for alternativesites and that Yew Tree remains on the site. I would like to agree with Councillor Beechwho said ""What's become clear to me, since the declaration of the ecologicalemergency and the climate emergency, is how much more we understand thecontribution that certain green spaces in the city make to our broader city picture."

Dear Ani,

Avon Wildlife Trust objects to the proposal to extend South Bristol Cemetery into land currently managed as part of Yew Tree Farm.

Bristol City Council has recognised that we are in the midst of an ecological emergency and need to take urgent action to protect and restore habitats for wildlife. In this context it is imperative that we protect important wildlife habitats that remain.

Yew Tree Farm is an immensely rich wildlife habitat supporting a wide range of species including plants, bats and birds that are increasingly scarce in surrounding areas. This has been recognised through the designation of parts of the farm as an SNCI by Bristol City Council, which brings with it a presumption of protection from development. It is vitally important that Sites of Nature Conservation Importance are protected through the planning system, and even more so in cases such as Yew tree Farm where the current wildlife value is so high.

In addition to its importance as an individual site, Yew Tree Farm is an important part of local ecological networks linking green spaces in the city with the wider countryside.

The national approach to restoring nature as set out in Government strategies is based on the Lawton Report of 2010, Making Space for nature. This recognises that we need more, bigger, better and connected wildlife habitats to enable wildlife to survive and thrive and cope with climate change. Bigger sites are important because they have larger areas that do not suffer from the "edge effects" of being next to land where

harmful pesticides, disturbance, or other activities which damage wildlife are ongoing. They can also support larger populations of species and reduce the risk of events such as disease or inclement weather causing a species to be lost from the site entirely.

Yew Tree Farm is at risk of going in the opposite direction and losing areas of high wildlife value created by its sympathetic management. As well as the likely loss of wildlife in these areas, this increases the risk that wildlife will decline and be lost from the wider site.

In addition to the ecological imperative to retain the site as a whole, without losing land not development, there is a management imperative as the wildlife value of the site is dependent on the continuation of sympathetic extensive grazing and the grazed area needs to be large enough for this to remain commercially viable.

For these reasons, Avon Wildlife Trust is opposed to all of the development proposals affecting Yew Tree Farm, including the proposed Redrow development extension in the eastern area of the farm and the extension of south Bristol Cemetery into the northern area and we are calling on Bristol City Council to work with the landowner to ensure that the fields are retained as they are, with a continuation of the current wildlife-friendly grazing regime.

I recognise and apologise for the fact that we have missed the deadlines for comment and statements for both the Planning Application and tonight's Planning Meeting, but wanted to place our position on the record in both contexts and hope it can be taken into account in the decision to be made this evening.

With thanks and best wishes,

Ian

Ian BarrettChief ExecutiveAvon Wildlife Trust

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:I am a local ecologist with 25 years' experience in nature conservation and my objection

is detailed below:

Planning application ref: 22/05714/FB - South Bristol Crematorium And Cemetery Bridgwater

Road Bristol BS13 7AS

The proposed cemetery extension into Areas 3 & 4 and the proposed linking drainage associated

with these proposals are within the Colliter's Brook Site of Nature Conservation Interest (SNCI).

This Local Plan designation is protected by Site Allocations and Development Management Policy

DM19: 'Development which would have a harmful impact on the nature conservation value of a

Site

of Nature Conservation Interest will not be permitted.' - page 40.

The passages from DM19, which the officer quotes in his report - at 10.15 to 10.17 - ignore the

express prohibition relating to SNCIs quoted above. This overrides the more generic policy

quoted.

The evidence produced by the applicant, including its ecological evidence, shows that the

proposed

development of these two areas will be harmful: fencing will be erected, drains will be installed,

an attenuation pond will be excavated, and, in due course, graves will be excavated and those

buried there will be visited and, perhaps, memorialised. I accept that burials may not start in Area

3 for some years and that there are proposals to mitigate this harm. However, harm will still be

caused both to the Urban Landscape and to the SNCI, both immediately and in the long term. This

is not permitted.

The applicant's plans will also result in a net loss of 6.75% of area habitat units. To compensate

for

this loss, it is proposed to provide offsite BNG in other parts of the SNCI outside the development

area. The Council's ecologist has, in a recent planning appeal (paragraph 7.5, p. 19), advised

against

seeking to offset lost onsite biodiversity by using an offsite SNCI: 'Due to its existing level of

interest

this land [the SNCI] is unsuitable for biodiversity enhancement.' This loss of BNG also amounts to

'a harmful impact' which DM19, as it relates to SNCIs, does not permit.

The areas of species-rich grassland on the site are of high nature conservation value in a local

context and include species such as strawberry clover and a diversity of limestone grassland

species,

such as lady's bedstraw, mouse-ear hawkweed and common bird's-foot trefoil. Other habitats and

species on site are of high importance for wildlife locally.

SNCI's are a vital part of the network of protected wildlife sites in Bristol and underpin all local,

national and international conservation objectives. As Sites of Special Scientific Interest (SSSI's),

nature reserves and country parks only cover a small percentage of land, SNCI's provide

important wildlife refuges, reducing fragmentation, linking different habitats and helping to maintain

biodiversity. SNCI's are also valuable in enhancing the health and wellbeing of local communities.

SNCI's are a key tool for planners to ensure the sensitive development of Local Plans. ALL SNCI's

in Bristol need to be fully protected and effectively managed for wildlife to ensure that there is an

ecologically coherent network of sites.

I therefore object to this planning application and recommend that this committee refuses this

application.

5th September 2023

To whom it may concern

I am writing to object to the expansion of the crematorium by taking away land that has been usedby Yew Tree Farm, Bristol's last working farm. Yew Tree Farm is dedicated to traditional farmingpractices, with vital importance to the sustainability of our natural environment and biodiversity,both of which contribute to reducing climate change.

Implicitly, I am strongly against the expansion of the crematorium on the grounds that SNCIprotections will not be honoured, with an ensuing adverse impact upon the natural environmentand preventing a working farm from promoting a healthy environment. We are witnessing the direeffects of climate change around the world. I cannot believe that Bristol City Council would evenconsider the expropriation of farmland which is being farmed traditionally. I implore you to makethe right choice - that is, to think of the future of our children and young people who will have tolive with the consequences of your decision.

Karen John, PhD,Psychologist and Psychotherapist,Chair, Mentoring Plus - Inspiring Young Lives

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:To whom it may concern

I am writing to object to the expansion of the crematorium by taking away land that has been used

by Yew Tree Farm, Bristol's last working farm. Yew Tree Farm is dedicated to traditional farming

practices, with vital importance to the sustainability of our natural environment and biodiversity,

both of which contribute to reducing climate change.

Implicitly, I am strongly against the expansion of the crematorium on the grounds that SNCI

protections will not be honoured, with an ensuing adverse impact upon the natural environment

and preventing a working farm from promoting a healthy environment. We are witnessing the dire

effects of climate change around the world. I cannot believe that Bristol City Council would even

consider the expropriation of farmland which is being farmed traditionally. I implore you to make

the right choice - that is, to think of the future of our children and young people who will have to

live with the consequences of your decision.

I object to the expansion of South Bristol Crematorium And Cemetery and this isbecause Yew Tree Farm has SNCI status. This local friendly farm is very important to the naturalhabitat of the area. It is a organic and ecological friendly farm. I also feel that this expansion isbeing used by the council as an excuse to try to pave the way to take more greenbelt land forfuture projects as this seems to be aim more and more.

I object to the expansion of South Bristol Crematorium And Cemetery. Yew Tree Farmhas SNCI status. This is a vitally important wildlife local friendly farm. Bristol City Council keepsaying it prides itself on being green, yet this new expansion would be a disatser for an organic,ecological farm where lots of wildlife live and natual flora exist. It is also obvious that the councilhave delayed releasing documents for the public to read and not submitted the full details of howthis expansion would not only affect Yew Tree Farm but other properties and places.

Good afternoon

I am writing to you because I heard about this possible expansion plan on Radio 4'srecently aired programme about Yew Tree Farm, Bristol.

I am concerned about the environment generally but I could not understand why primefarm land on Yew Tree Farm would be used for the Crematorium's expansion. Theremust be other brownfield sites within Bristol or nearby that could be used instead? Plotsfor a crematorium do not have to be nearby. There could be designated areaselsewhere, as long as people are properly informed by Crematorium staff and literatureexplaining the situation. Personally, having lost loved ones myself, this would notbother me in the slightest. Crematorium buildings are large and they are hardlyaesthetically pleasing! Most remembrance plots in urban areas are generally rented andrestricted to a few years for this reason anyway.

The Farm has been carefully managed over several generations and the land wasprotected, adding to biodiversity which is vital in a cityscape. If this land is developed,valuable habitats will be lost and marginalised, becoming further fragmented and thiswill inevitably result in loss of many species of wildlife.

In addition the Farm produces organic foods, it is rightly proudly farm to fork and soreducing carbon emissions that would otherwise be incurred.

The Farm is also a very valuable resource for people suffering with mental healthissues. Many report increased well being after spending time there.

A field normally used for cutting hay for winter cattle feed has also been locked andgated off, so potentially pushing up costs as the Farm will have to buy in winter feed.This will also have transportation carbon emissions associated with it, when the UK isgenerally trying to reduce it's carbon footprint due to climate change!

I spent part of my childhood living in Bristol, I am not a resident as such, but I do knowwhat wonderful city it is and what a valuable resource Yew Tree Farm is not only to thecommunity but also to the well being of wildlife in the area.

Yours sincerely

Dear committee I object to this application for the following reasons:

- [ ] Site is in the greenbelt- [ ] No other burial land options have been explored- [ ] The site is an SNCI (site of nature conservation interest) and therefore should notbe touched according to policy DM19- [ ] Bristol city council passed a motion in sept 2021 that said our greenbelt and naturerich green sites should be protected. Passing this would violate the green spacesmotion- [ ] There are veteran trees that would be damaged to the point of death- [ ] This is a beloved site of recreation for residents- [ ] This would put Yew Tree Farm out of business- [ ] This is against our climate and ecological emergency.

Fourth Comments - 17 August 2023

2

No reason is given why it was marked sensitive. Reading the document, it is hard to understand

why this was done as it contains no sensitive information as far as we can see. As a result, those

with an interest in such matters have been denied the opportunity to comment.

What is clear, however, is that the current plans may be inadequate. Whilst the Planning Officer

acknowledges this in their report to DCC A, they fail to report the Officer’s following advice:

If the receiving watercourse can accept such an increased flow rate however, that will

not increase flood risk to third parties downstream and subject to Flood risk activities

environmental permitting, then further flow restrictions may need not apply.

There is no evidence that the calculations have been redone, or been represented to the

Drainage Officer, or sent to the Environment Agency for their further comments. This is

particularly the case with the additional drainage proposed from Site 1, which will increase the

current flow from the nearby burial grounds to the south, bypass the proposed attenuation pond

and discharge directly into Colliter’s Brook.

Given that this information forms a critical, material element of the viability of the scheme, it

is not sufficient for this to be covered by a pre-commencement condition to be dealt with after

the application is approved. This should have been done before the application was submitted

for approval.

It is also notable that the Environment Agency advised that:

This development will require a permit under the Environmental Permitting (England

and Wales) Regulations 2016 ... Where a developer decides not to parallel track their

planning and environmental permit applications, we will not offer detailed advice or

comments about how permitting issues affects planning.1

Given the above and the likely increased threat of flooding on third parties downstream

(Colliter’s Brook is known to be at high risk of sudden spate flooding), it is surprising that more

has not been done to engage with the Environment Agency or with those downstream who may

be affected by this proposal.

2. The email correspondence with the Planning Nature Conservation Officer

Whilst we reserve our position pending further comments from the Nature Conservation Officer,

which we are told are forthcoming, we are compelled to make the following observations:

1. Given that we had been engaged in detailed exchanges about the ecological and

environmental impact of these plans since about July 2021, it is surprising that the Planning

Officer did not seek the Nature Conservation Officer’s comments until just before they

1 22_05714_FB-ENVIRONMENT_AGENCY-3372546

Fourth Comments - 17 August 2023

3

were about to draft a report to the DCC in February 2023, and that their approach was so

tentative. The email from the Planning Officer to the Nature Conservation Officer allowed

just two days for a response and implied that a response was not really needed. The

Planning Officer wrote, ‘I just wondered whether you had any comments to make on the

above application? I have to complete a Committee Report on this by Friday so if you do

not have any comments on it – that’s fine.’

2. In their first response of 23 February, the Nature Conservation Officer went straight to the

heart of the issue: DM19 makes it clear that ‘Development which would have a harmful

impact on the nature conservation value of a Site of Nature Conservation Interest will not

be permitted.’ The Nature Conservation Officer goes on the add: ‘Without any additional

information, I would have to object to this proposal citing DM19’.

We have been pointing out this absolute injunction since day one but have been ignored.

Worse still, the Planning Officer has chosen to ignore their very own Nature Conservation

Officer’s advice and omitted to advise the Committee of this in their recent report to DCC

A.

The Nature Conservation Officer then adds:

In order to consider it further, it would have to be demonstrated that post-

development the land which would be developed within the SNCI would still meet

the SNCI designation criteria set out in the attached guidance document (page 8

and 9). If, post-development, the land would still meet the criteria and the SNCI

designation on the land would still apply, then it could be considered that no

significant harmful impact has occurred to the SNCI*. However, if the land would

no longer meet the SNCI criteria post-development, then the SNCI status has been

lost/a harmful impact on the SNCI would occur which is not supportable by DM19.

An assessment undertaken by a suitably qualified ecologist needs to be carried out

to consider the above, which I will then need to review.

It is unclear what the attached guidance document referred to above is. We suspect it is

Appendix 3 of the Local Sites Partnership guidance, Designated Sites Protocol & Criteria

v12 March 2011, though this needs to be clarified. As far as we are aware, no such analysis

has been done and a careful reading of the email thread suggests that this issue has still

not been resolved to the Nature Conservation Officer’s satisfaction.

3. In their second email of 04 May 2023, the Nature Conservation Officer notes the post-

development mitigation measures and observes:

I’m really concerned that the mitigation measures proposed (for both on and off-

site areas) need to not only be secured with a long-term* management plan, but

also have to be agreed to by all the stakeholders ... This needs to be secured pre-

determination because whether or not the SNCI will be subject to harmful impact

is a material planning consideration. ... If commitments can be made by all parties

to the extensive habitat management required on this site to maintain SNCI status

Fourth Comments - 17 August 2023

4

(where relevant) and a legal agreement can be made to secure this, then I could

consider whether there would be no significant harmful impact to the SNCI further.

However, I don’t currently see how this would be feasible and the habitat

management required would be consistent long-term. This proposal is therefore

still not supportable, citing policy DM19. ...

*the importance of the management being secured long-term is especially

emphasised by the fact that some of the habitats proposed in the BNG assessment

have a time to target condition of over 30 years (the line of trees proposed in Area

3, SNCI)

Furthermore, they point out, any management plan must include the Withers family - who

have farmed the land for many decades. Even then, the Nature Conservation Officer’s

possible approval is tentative – ‘then I could consider whether there would be no significant

harmful impact to the SNCI further.’ The Withers family were not consulted, nor were they

included as stakeholders in the Planning Officer’s report to DCC A.

It is clear from this that any management plan (described as a Landscape and Ecological

Management Plan (LEMP) in the Planning Officer’s report to DCC A) must be agreed before

this application is considered. The Nature Conservation Officer’s subsequent email of 27

July 2023 provides no evidence that these concerns have been addressed, offers no comfort

that they will be and is hard to reconcile with their earlier comments.2

Neither of these two issues were raised by the Planning Officer in their report to DCC A, despite

their statement that the Nature Conservation Officer’s comments were in the Key Issues

section.

4. Despite this, and despite the numerous assurances given to the family both by the officer

managing the application for the Council and by a member of the Mayor’s Cabinet (see the

email at Annex 3) about the future of the farm’s use of the site, no offers of a new tenancy

or offer to meet to discuss this or the future management of the site have been

forthcoming.

Instead, the Planning Officer’s report to DCC A states at paragraphs 10.20 & 10.21 -

Ecological Management of the site:

The application site is entirely in the control of Bristol City Council. There is no

tenant farmer on the site. The previous tenancy was terminated in 2021 and the

land has since been fully within the Council’s control to determine and implement

management arrangements.

2 It is unclear what ‘Oliver’s explanation of the pre and post-development areas not matching up in the BNG assessment’ is. We have not been advised. 3 We have pointed out a number of inaccuracies in this email in section 2 of our latest comments.

Fourth Comments - 17 August 2023

5

In support of their application, it is noted that as a stopgap measure, an informal

agreement had been given for the adjacent (Yew Tree) farm to have temporary

access to graze the land. It has been confirmed with that party that the temporary

access arrangements confer no assumed tenancy rights. This indicates Council is

therefore the only relevant party to confirm the commitment to manage the site

...

Given this, it is hardly surprising that the Withers family have lost all confidence in these

assurances and feel caught, as it were, in a pincer movement between the apparent

vindictiveness of the owners of the hay meadows adjoining Bridgewater Road and the

apparent duplicity of the Council.

If, despite all this, the Council is still determined to ignore the absolute prohibition against

causing a significant harmful impact to the SNCI, as adopted by it in DM19 (as well as a similar

prohibition in DM17), and proceed with its application, and if the DCC, despite all the evidence

that this application is contrary to the Local Plan, is minded to grant its application, then we

propose that the conditions set out at Annex 4 be adopted rather than those proposed by the

Planning Officer in their last report to DCC A.

However, based on all the evidence now available, this application must be refused as it is

currently proposed.

Fourth Comments - 17 August 2023

6

Annex 1 - The comments of the Council’s Drainage officer

Consultee Comments for Planning Application 22/05714/FB

Application Summary

Application Number: 22/05714/FB

Address: South Bristol Crematorium And Cemetery Bridgwater Road Bristol BS13 7AS

Proposal: Expansion of existing cemetery and crematorium to provide new burial and

memorial plots with associated roads, footpaths, parking, drainage infrastructure, fencing,

landscaping and furniture.

Case Officer: Peter Westbury

Consultee Details

Name: Mr John Stevens

Address: Brunel House St Georges Road, City Centre, Bristol, Bristol BS1 5UY

Email: Not Available

On Behalf Of: Flood Risk Manager

Comments

The overall approach to the drainage strategy would be appropriate for this site given its

existing drainage characteristics and the site constraints. Since infiltrating SuDS methods are

inappropriate here the next preferred option in line with the SuDS hierarchy is directly

discharging to a nearby watercourse and that is proposed into the adjacent Colliter's Brook. We

are supportive of the use of an attenuation basin to give extra storage provision and to slow

flows ahead of entering this watercourse.

The estimate of the greenfield runoff rate and proposed discharge rate seem very high and the

calculations formulating this have not been provided. This should be recalculated, resubmitted

and reused in informing the drainage strategy design. If the receiving watercourse can accept

such an increased flow rate however, that will not increase flood risk to third parties

downstream and subject to Flood risk activities environmental permitting, then further flow

restrictions may need not apply. Full details of the newly proposed headwall and its alignment

would also be required.

Fourth Comments - 17 August 2023

7

Annex 2 – Email correspondence between the Planning Officer and the Planning

Nature Conservation Officer

Email 1 – PO to NCO

From: Peter Westbury

Sent: 22 February 2023 16:58

To: Fern Kenyon-Hamp

Subject: Application 22/05714/FB - South Bristol Cemetery

Hi Fern,

I do hope that you are keeping well.

I just wondered whether you had any comments to make on the above application? I

have to complete a Committee Report on this by Friday so if you do not have any

comments on it – that’s fine.

Thanks, Peter

Peter Westbury

Team Manager

Development Management – Growth and Regeneration

Email 2 – NCO to PO

From: Fern Kenyon-Hamp

Sent: 23 February 2023 16:46

To: Peter Westbury

Subject: RE: Application 22/05714/FB - South Bristol Cemetery

Hi Peter,

Currently this application is not supportable from a Nature Conservation perspective.

Headlines below.

Part of the development is within the Collitors [sic] Brook Site of Nature Conservation

Interest (SNCI) which means that DM19 applies: “Development which would have a

harmful impact on the nature conservation value of a Site of Nature Conservation

Interest will not be permitted”. Without any additional information, I would have to

object to this proposal citing DM19.

In order to consider it further, it would have to be demonstrated that post-

development the land which would be developed within the SNCI would still meet the

SNCI designation criteria set out in the attached guidance document (page 8 and 9).

Fourth Comments - 17 August 2023

8

If, post-development, the land would still meet the criteria and the SNCI designation

on the land would still apply, then it could be considered that no significant harmful

impact has occurred to the SNCI*. However, if the land would no longer meet the SNCI

criteria post-development, then the SNCI status has been lost/a harmful impact on

the SNCI would occur which is not supportable by DM19. An assessment undertaken by

a suitably qualified ecologist needs to be carried out to consider the above, which I

will then need to review.

*A bespoke land management plan would be required to maintain the lands status as

an SNCI long-term if it is going to be multi-use, and (looking at the BNG assessment

now) if biodiversity net gains are proposed to be achieved off-site (in other areas on

the SNCI) then any land management practices would have to be agreed pre-

determination with BCC and any land tenants - there was mention of off-site land that

is currently grazed, or would be preferable to continue being grazed in the future and

this would not be acceptable ‘in principle’ because tenants would have to be

consulted.

Thanks,

Fern Kenyon-Hamp

(she/her)

Nature Conservation Officer (Planning)

Placeshaping Team

Bristol City Council - City Design - Growth and Regeneration

Email 3 – NCO – PO

From: Fern Kenyon-Hamp

Sent: 04 May 2023 14:38

To: Peter Westbury

Subject: RE: Application 22/05714/FB - South Bristol Cemetery

Hi Peter, long email below.

Thanks for reconsulting me on this proposal. Apologies for the delay.

The suggested mitigation measures in the Ecological Mitigation Proposals report

(Wessex Ecological Consultancy, 2023) clearly show that extensive habitat

management would be required on this site, long-term, to maintain the SNCI status of

the parcels of land within the Collitors [sic] Brook SNCI and for habitats created for

BNG to reach their target-condition.

Fourth Comments - 17 August 2023

9

I’ve read through the email chain which I have been cc’d in to by the BTF and Oliver

Roberts, and I see that in Feb Oliver said:

“For the offsite mitigation, we have proposed production of a project funded SNCI

management plan as a planning condition, so that the detail of the areas and

associated management activities can be fully considered. This identified that we

would engage stakeholders in its development and I can confirm that we will

therefore arrange a site visit at the point of producing the management plan (post

planning consent, rather than now). In terms of impact on grazing, the purpose is to

restore grassland lost to scrub; the ecologist led management plan will ensure the

works are well considered and planned around ongoing grazing activity, the

management activities would ultimately increase the area of higher value grassland,

so alongside providing ecological benefit would have a positive benefit on the grazing

area available.”

I’m really concerned that the mitigation measures proposed (for both on and off-site

areas) need to not only be secured with a long-term* management plan, but also have

to be agreed to by all the stakeholders. The Withers family at Yew Tree Farm will

need to agree to amendments in the grazing regime on some of the land, the

cemetery team will have to agree to commit time and resources to habitat

management and changes to their general practice long-term, and the consultant

ecologist (I presume?) will have to commit to the re-surveying effort that will be

required periodically (and if not them, who?). And who manages this coordination

overall long-term? Also, legally how can BCC ensure commitment from all these

parties? This needs to be secured pre-determination because whether or not the SNCI

will be subject to harmful impact is a material planning consideration.

If commitments can be made by all parties to the extensive habitat management

required on this site to maintain SNCI status (where relevant) and a legal agreement

can be made to secure this, then I could consider whether there would be no

significant harmful impact to the SNCI further. However, I don’t currently see how

this would be feasible and the habitat management required would be consistent

long-term. This proposal is therefore still not supportable, citing policy DM19.

*the importance of the management being secured long-term is especially emphasised

by the fact that some of the habitats proposed in the BNG assessment have a time to

target condition of over 30 years (the line of trees proposed in Area 3, SNCI)

In addition to this, I’ve looked at the BNG Assessment and this requires some

amendments. The baseline habitat lost does not match the development footprint,

Fourth Comments - 17 August 2023

10

plus the area of new habitat creation and enhancement. This needs to be explained or

fixed. And if there is a new headwall/outfall going in to the Collitors [sic] brook the

BNG assessment has to include the watercourse metric and a net gain in biodiversity

for this habitat must also be achieved.

I should also point out that in the BTF’s latest comments, they have quoted the

‘council’s own ecologist’…me… as saying (during the Bris Meadows enquiry) “I also

considered the biodiversity interest of other areas of land in the vicinity, some of

which might be made available to the applicant under the terms of the Land

Agreement with Bristol City Council. My own survey, supported by the findings of a

Bristol City Council survey dating from 2008 (summarised in Appendix 6) show that

much of this land is of existing nature conservation interest, as reflected by its

inclusion within the SNCI. Due to its existing level of interest this land is unsuitable

for biodiversity enhancement.”. I did not say this. I believe this was our expert

witness Ecologist (coincidentally the ecologist for this application also). Just want to

point this out as the BTF comment is in the public domain now.

Happy to have a meeting about this one if we need to but I think that’s all my

feedback for now.

Thanks,

Fern Kenyon-Hamp

(she/her)

Nature Conservation Officer (Planning)

Urban Design

Email 3 – NCO – PO

From: Fern Kenyon-Hamp

Sent: 27 July 2023 17:45

To: Peter Westbury

Subject: RE: Application 22/05714/FB - South Bristol Cemetery

Hi Peter,

Condition below for management of the site. I also think we should get that letter

from Jonathan James securing the land management agreement on top of this

condition.

Landscape and Ecological Management Plan (LEMP)

Fourth Comments - 17 August 2023

11

Prior to commencement of the development hereby approved, the applicant shall

submit a 30-year Landscape and Ecological Management Plan (LEMP) for all habitats

contributing to Biodiversity Net Gain (BNG). This should address retained features of

ecological interest, together with mitigation and enhancements to be provided. The

LEMP should set out management compartments, objectives, and prescriptions for all

new proposed soft landscaping/planting to demonstrate how all habitats will be

managed to their target condition (as specified in the BNG Assessment). It should also

show how management of the site will be resourced and monitored.

This LEMP should also set out how the development area will be managed to maintain

its status as a Site of Nature Conservation Interest (SNCI) as per the Ecological

Mitigation Proposals report produced by Wessex Ecological consultancy (2023). This

must demonstrate how no harmful impact on the nature conservation value of the site

will take place as a result of the development, therefore demonstrating how the

development complies with Policy DM19 of the local plan.

Reason: Ecological enhancement is needed to meet the requirements of the revised

National Planning Policy Framework (NPPF, 2021). The NPPF states in paragraph 174

(d) on page 50 that “Planning policies and decisions should contribute to and enhance

the natural and local environment by... minimising impacts on and providing net

gains for biodiversity...". The Environment Act (2021) requires habitats to be

maintained for 30 years after development is completed (schedule 7A, Part 1,

paragraph 9) to secure net gains for biodiversity. Policy DM19 of the Bristol City

Council Local Plan states: “Development which would have a harmful impact on the

nature conservation value of a Site of Nature Conservation Interest will not be

permitted”.

I’ve re-read Oliver’s explanation of the pre and post-development areas not matching

up in the BNG assessment… I think we’re ok but I will read it again tomorrow.

And as the development includes works on the river, the BNG regs say that these

works have to be assessed under the BNG metric so an uplift in riverine habitats is

achieved. I can see what Ollie is saying about the qualitative assessment of the works

on this river, and the time pressure, however BCC will probably be challenged on not

following the regs.

Thanks,

Fern Kenyon-Hamp

(she/her)

Nature Conservation Officer (Planning)

Fourth Comments - 17 August 2023

12

Urban Design

Fourth Comments - 17 August 2023

13

Annex 3 – Email Councillor King to Maddy Longhurst dated 5 August 2023

From: Councillor Ellie King

Date: Sat, 5 Aug 2023 at 20:17

Subject: RE: Yew Tree Farm and Crematorium. Not either/or

To: Maddy Longhurst, Councillor Ed Plowden, Councillor Andrew Varney, Councillor Farah

Hussain, Councillor Tom Hathway, Councillor John Geater, Councillor Richard Eddy Councillor

Fi Hance, Councillor Christopher Jackson, Councillor Philippa Hulme, Democratic Services

Cc: Councillor Nicola Beech,Councillor Asher Craig, Louise Delmege,Leon Ballin, Heloise

Balme, Gillian Morgan.

Hi Maddy,

Thank you for your email and for your advocacy. As you’ll be aware, the decision to develop

the site sits with a cross party development committee (cc’d for awareness) that will be

meeting on Wednesday 9th August to determine the outcome of the application.

However, after careful consideration I have formed a view based on briefings and discussions

with officers on the proposals. It is a nuanced one. As you and others on this circulation know

sustainable and healthy food is extremely important to me, but I don’t believe this

development signals the end of Yew Tree Farms ability to operate, on the contrary I think it

will help ensure their future.

The context: When the farm entered in to an informal agreement a few years ago to

temporarily graze on the land, they knew from the outset that it was intended for the

cemetery expansion. It would be disingenuous to suggest otherwise. This is Bristol City

Council land and we have an obligation to provide burial space for Bristol residents. Almost all

of our sites are at capacity. There is no other alternative site, and this would be a significant

equalities issue if we were to not expand the cemetery to accommodate need. The decision

reached by the committee needs to balance the benefits to the whole of Bristol with the

concerns voiced by Yew Tree Farm and others.

The first phase of development is to take 10-15 years, and will utilise just 4% of the current

grazing land. I have been advised that this is equivalent to the grazing land for just 1 cow and

1 calf. As the development will be done slowly over a number of years, the farm will have

adequate time to adjust and adapt.

In depth, sound ecological reports have indicated that the SNCI status of the site has not been

managed suitably and there has been a reported decline in the ecological value of the

grassland within the SNCI in the past 20 years. This is in part due to the encroachment of

scrub which has not been actively managed.

The proposed development is subject to implementing a 30 year Landscape and Ecological

Management Plan (LEMP) to halt the decline through grassland restoration and ensure the site

contributes to biodiversity Net Gain (BNG) and the SNCI status is maintained as such. This

would be an explicit condition upon approval of the proposal. The wildflower meadow isn’t in

Fourth Comments - 17 August 2023

14

scope and the hedgerow and tree planting will be increased as well as protection put in place

for the current ancient hedgerow.

On to the Farm’s future. The council cannot enter into a long term lease with Yew Tree Farm

until it is able to develop a long term management strategy for the site. But the development

of this management plan is subject to getting this planning application approved. A chicken

and egg situation that indicates it is in the best interests of the future of the farm to get this

planning decision approved, so that we can work together to get a lease for the farm with the

required management provisions which will give them long term security and resilience. I am

very keen to support the farm with this.

Yew Tree Farm is a valuable asset, but we have to consider the status of the SNCI, the need

for burial space and weigh that up with what is only 4% loss of grazing land (approx the space

for 1 cow-calf pair) over the next 10 – 15 years. Ideally we could do all these things but this is

frequently an occupational hazard of working in a city with finite space, resource and

competing priorities.

Thanks again for your email, I hope you receive this response in the collegial nature it is

intended. This is my view, but the decision rests with the committee.

Thanks,

Ellie

Cllr Ellie King

Labour Councillor for Hillfields

Cabinet member for Public Health and Communities

Fourth Comments - 17 August 2023

15

Annex 4 – Proposed Conditions

1. No development shall take place until a Construction Ecological Management Plan (CEcMP), to be informed by the updated Ecological Impact Assessment has been submitted to and approved in writing by the Local Planning Authority. The CEcMP shall include, but not be limited to:

a) a risk assessment of potentially damaging construction activities;

b) identification of “biodiversity protection zones”;

c) practical measures (both physical measures and sensitive working practices) to avoid or reduce impacts during construction e.g., pollution events;

d) the location and timings of sensitive works to avoid harm to biodiversity features;

e) the times during construction when specialist ecologists need to be present on site to oversee works;

f) responsible persons and lines of communication;

g) the role and responsibilities on site of an Ecological Clerk of Works or similarly competent person; and,

h) use of protective fences, exclusion barriers and warning signs if applicable.

Construction and demolition shall thereafter adhere to the approved CEcMP.

2. No development shall take place until a Phasing Plan of the development has been submitted to and approved in writing by the Local Planning Authority.

3. An updated Ecological Impact Assessment (EcIA), prepared in accordance with published CIEEM guidelines and informed by the South Bristol Cemetery Ecological Assessment carried out on 29th November 2019, 12th June 2020, 18th June 2020 and 10th September 2020. The updated EcIA should be updated for each Phase thereafter. This shall include repeat protected species surveys as appropriate.

4. No development shall take place until a Landscape and Ecological Management Plan (LEMP) has been submitted to and approved in writing by the Local Planning Authority. The LEMP is to be informed by the requirements identified in the updated Ecological Impact

Assessment as required by Condition 3. The LEMP shall include, but not be limited to:

a) description and evaluation of features to be managed;

b) ecological trends and constraints on site that might influence management;

c) aims and objectives of management;

d) appropriate management options for achieving aims and objectives;

e) prescriptions for management actions;

f) programme of ecological monitoring, setting out key performance indicators for each feature of interest covered by the plan against which monitoring results should be reviewed;

Fourth Comments - 17 August 2023

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g) prescription of a work schedule (including a 30-year annual work plan – to be reviewed and submitted to the Council every five years);

h) details of the body or organisation responsible for implementation of the plan and defined role and responsibilities;

i) ongoing monitoring and remedial measures; and,

j) details of a resourcing and funding budget.

5. Prior to the commencement of each Phase of the development, as defined by the Phasing Plan in Condition 2, (including demolition and all preparatory work) a scheme for the

protection of retained trees and hedgerows within that Phase, in accordance with BS5837:2012, shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall include, but not be limited to:

a) identification of the trees and hedgerows to be retained, and those to be removed or translocated, to include a scaled plan;

b) all proposed pruning work;

c) the means by which retained or translocated trees and hedgerows will be protected throughout the construction period, including by temporary fencing and/or other physical barriers;

d) where within the Phase mitigation of any kind (other than temporary barriers) is necessary in order to prevent harm to retained trees and/or hedgerows;

e) how all operations with the capacity to harm a retained tree and/or hedgerow will be controlled to avoid harm during the operation (e.g., access, earthworks, level changes);

f) the specification, design and arrangement of built structures near to trees and/or hedgerows, wherever this is necessary to prevent harm during the construction, operation or maintenance of the structure (e.g., surfaces, drainage, utilities, buildings);

g) a schedule of independent monitoring of tree and/or hedgerow works, tree and/or hedgerow protection, relevant construction activities, and reporting to the Local

Planning Authority on progress and compliance with the approved measures; and,

h) a Veteran Tree Management Plan for each veteran tree that is retained within the Phase, including a detailed description of the tree, management objectives, buffer zone definitions, protection measures, restrictions, works prescriptions, landscaping, and a regime of monitoring.

A pre-start site meeting shall be held between the site manager (principal contractor), project arboriculturist, project ecologist, external works contractor, and tree works contractor to

review the approved works and protection details, establish roles and responsibilities, and to commence regular monitoring. The Local Planning Authority shall be given at least two weeks’ notice of the date of this meeting. The development of each Phase thereafter shall be implemented in strict accordance with approved details.

6. Prior to the commencement of each Phase of the development, as defined by the Phasing Plan in Condition 2, details of the treatment of all parts of the site comprised in that Phase and not covered by buildings shall be submitted to and approved in writing by the Local

Fourth Comments - 17 August 2023

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Planning Authority. Details shall include, but not be limited to:

1) the location, type and materials to be used for hard landscaping including Stockholm specifications for:

i) permeable paving;

ii) underground modular systems;

iii) soil aeration vents;

iv) soil type, biochar content and soil volumes available for each tree;

v) sustainable urban drainage integration, utilising rainwater run-off to supplement tree planting pits;

vi) works within tree Root Protection Areas (RPAs);

b) a scaled plan and a schedule detailing species, sizes and numbers/densities of all proposed trees, plants and hedgerows. The number of proposed trees shall comply with a calculation to be made in accordance with the Bristol Tree Replacement Standard. Proposed trees shall be in locations where they are able to grow to full size, and trees in rear and front gardens shall not be counted for this purpose;

c) specifications for operations associated with plant establishment and maintenance that are compliant with best practise; and

d) types and dimensions of all boundary treatments.

7. Each Phase shall be landscaped strictly in accordance with the approved details for that Phase and in the first planting season after completion or first occupation of the development within that Phase, whichever is the sooner. All soft landscaping shall have a written five-year maintenance programme following planting. Any tree(s) that die(s), are/is removed or become(s) severely damaged or diseased shall be replaced and any new planting (other than trees) which dies, is removed, becomes severely damaged or diseased within five years shall be replaced. Any replacement planting shall be in accordance with the approved details.

8. Prior to the commencement of each Phase of the development, as defined by the Phasing Plan in Condition 2, an updated Biodiversity Net Gain (BNG) Assessment for that Phase shall have been submitted to and approved in writing by the Local Planning Authority. The BNG Assessment shall be based on an updated Ecological Survey of the site and the detailed design proposals for that Phase as agreed in the relevant reserved matters submission(s). The BNG Assessment shall use the Biodiversity Metric 4.0 Calculation Tool unless an amended statutory Biodiversity Metric Calculator associated with the Environment Act 2021 becomes mandatory.

9. Prior to the commencement of each Phase of the development, as defined by the Phasing Plan in Condition 2, a Project Implementation Plan (PIP) shall be submitted to and approved in writing by the Local Planning Authority. The PIP shall detail the delivery of on and off-site ecological and Biodiversity Net Gain (BNG) mitigation and compensation, in accordance with the approved BNG Strategy. The purpose of the PIP shall be to ensure that a framework is adopted by all relevant parties which ensures a consistent, integrated and common approach for the delivery of the agreed scheme targets for ecology and BNG. The PIP shall

Fourth Comments - 17 August 2023

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include timescales, phasing, critical pathways, programme risks, roles and responsibilities, communication pathways, and project controls as may be required to ensure the successful delivery of the combination of mitigation and compensation measures on and off site. The PIP shall thereafter be adhered to.

10. Prior to the commencement of each Phase of the development, as defined by the Phasing Plan in Condition 2, an Ecological Mitigation and Enhancement Strategy (EMES) for that Phase shall have been submitted to and approved in writing by the Local Planning Authority.

11. Within one year of substantial completion of each Phase, evidence that the measures approved under the EMES have been delivered for that Phase shall be submitted to the Local Planning Authority (LPA).

12. Protection of Retained Trees During the Construction Period

No work of any kind shall take place on the site until an Arboricultural Method Statement (AMS) has been approved in writing by the LPA. The AMS will identify where pipe runs will pass through hedgerows and avoid the Root Protection Areas of trees. If this is not possible, a method will be agreed for avoiding unnecessary damage to hedge and tree roots.

No work of any kind shall take place on the site until the protective fence(s) has (have) been erected around the retained trees in the position and to the specification shown on

Drawing No. [To be identified].

The LPA shall be given not less than two weeks prior written notice by the developer of the commencement of works on the site in order that it may verify in writing that the approved tree protection measures are in place when the work commences.

The approved fence(s) shall be in place before any equipment, machinery or materials are brought on to the site for the purposes of the development and shall be maintained until all equipment, machinery and surplus materials have been removed from the site.

Within the fenced area(s) there shall be no scaffolding, no stockpiling of any materials or soil, no machinery or other equipment parked or operated, no traffic over the root system, no changes to the soil level, no excavation of trenches, no site huts, no fires lit, no dumping of toxic chemicals and no retained trees shall be used for winching purposes.

If any retained tree or hedgerow is removed, uprooted or destroyed or dies, another tree or hedgerow shall be planted at the same place and that tree or hedgerow shall be of such size and species, and shall be planted at such time, as may be specified in writing by the

LPA.

Reason: To protect the retained trees from damage during construction, including all ground works and works that may be required by other conditions, and in recognition of the contribution which the retained tree(s) give(s) and will continue to give to the amenity of the area.

This application affects viability, sustainability of yew tree farm.The farm is an organic farm which is also an SSNIAt a time of climate crisis, food insecurity.It also provides community engagement.The council has accepted that this farm needs protecting.

I'm a Bristol resident who walks along this stream. I've spent many hours working torestore nature in the river Trym, Hazel Brook and other local watercourses (including theBrislington Brook and river Avon). I comment as a private individual from this perspective.

Freshwater eels (a Biodiversity Action Plan - BAP - species, red listed) and water voles have beenrecorded in the Colliters Brook (or at least in grid squares including the brook) downstream of thesite. Evidence of otters has also been found. Source: BRERC.

Freshwater habitats in Bristol are already under huge pressure including from pollution, fly-tipping,presence of numerous weirs and replacement of greenspace with hard surfaces (imposing evermore flashy flow regimes), climate change will exacerbate this. This also applies to the CollitersBrook.

The development appears to risk increasing these pressures on this stream, in which BAP specieslive and which is already under pressure. As a minimum, mitigation works will be needed to limitthe impacts of the development on the stream and its banks (including on its hydrology andecology). Pre and post development monitoring should also be undertaken so the impacts can beobserved and if necessary acted upon to remediate them.

A lot of work went into habitat mitigation actions related to the Yanley refuse site on the other sideof the A4174. Viridor, among others, continue to regularly monitor a series of boreholes to testwhether any leachate is coming from the site and is impacting the environment (it shouldn't do asthe whole site has been capped/sealed). I'm not aware of any issues to date. That said, why is

such a significant control regime in place if there is no/little wildlife value in the landscape here? Itmakes me wonder if there was a review conducted at the time which concluded there wassomething of significant wildlife value to protect near the site. I suggest this needs to be checked.

Additional Comments – 11 August 2023

2

Yet this is exactly what DM19 is designed to do - it 'utterly restricts all development' that 'would have a harmful impact' and so gives a greater level of protection to SNCIs than would otherwise be the case where a site only has 'a habitat, species or features, which contribute to nature conservation in Bristol.' To interpret this policy otherwise would make a mockery of the special protections accorded to SNCIs in the Local Plan.

Your reference to 'adequate management of the SNCI' is, with respect, irrelevant. It is clear that the post-development management is designed to mitigate the impact of the admitted harms done by the proposal (see Rupert Higgins' report of Summer 2020 - attached), not prevent these harms. Also, Rupert Higgins' Ecological Mitigation Proposals in 22_05714_FB-ECOLOGICAL_MITIGATION_PROPOSALS_-_SOUTH_BRISTOL_CEMETERY_EXPANSION-3435046 are designed to set out '... in broad terms measures that will be taken, if the proposal goes ahead, to ensure that those parts of the extension that are within the Site of Nature Conservation Interest (SNCI) retain this status in the long term. So harm is

anticipated into the future also. DM19, as it relates to SNCIs, makes no allowance for post-harm mitigation. It is not conditional, it is absolute and not a question of planning balance. I must say I am surprised that you don't discuss this special protection given to SNCIs by DM19 in your report to the Committee (save in the Pre commencement condition(s) statement, where you quote it in the reasons for requiring a LEMP). Is there a reason for this? In the meantime, can you please send me a copy of the BCC Drainage and Nature

Conservation officers' report referenced in your report.’

We have not yet had a response to this. Using the latest BNG 3.1 report prepared for the Council, we have summarised the net change in habitat units as follows:

Additional Comments – 11 August 2023

3

It is clear from the above that there will be a harmful impact to the SNCI within the development area - the loss of 5.12 Habitat Units. This is contrary to DM19. Given the way the BNG 3.1 trading rules work - lost Medium Distinctiveness habitats may only be replaced by the same broad habitat or a higher distinctiveness habitat - the only option to compensate for the lost scrub habitat is to create offsite Lowland meadows habitat

elsewhere within the SNCI. We have already commented on the inadvisability of seeking to offset lost biodiversity on the adjacent offsite parts of the SNCI.1

2 The comments made by Councillor Ellie King

In her email to Maddy Longhurst of Green Future Associates dated 05 August 2023, Councillor King wrote:

'In depth, sound ecological reports have indicated that the SNCI status of the site has not been managed suitably and there has been a reported decline in the ecological value of the grassland within the SNCI in the past 20 years. This is in part due to the encroachment of scrub which has not been actively managed.'

No such evidence has been published in support of this application. On the contrary, the Council’s ecologist reports that ‘Sites 3 and 4 are grazed by cattle, a regime that in general is maintaining the site’s nature conservation value.’2 Sites 3 and 4 are both within the Colliter’s Brook SNCI. The ecologist then goes on to add, in the Objectives section:

Objective 2 To maintain the existing management regime at Sites 3 and 4 until the former is incorporated into the cemetery.

There will be a delay between the planning consent (if granted) and implementation of the scheme. In parts of Site 3 this is likely to extend to many years. It is important that the grassland continues to be managed during this period, preferably by grazing with beef cattle as at present.

2.1 Support Yewtree Farm in continued management of these areas before the cemetery is extended.

2.2 Maintain fencing between the burial area and the retained grazing land to allow access by cattle to as large an area as possible, moving the fencline (sic) as additional areas come into use for burials.

2.3 Retain access for cattle to areas not incorporated into the cemetery.

2.4 Monitor the extent to which grazing of these areas remains sufficient; if this is not the case either modify access arrangements or, as a last resource, implement a hay-cutting regime.

1 See our second tranche of further comments dated 14 April 2023 2 22_05714_FB-ECOLOGICAL_MITIGATION_PROPOSALS_- _SOUTH_BRISTOL_CEMETERY_EXPANSION-3435046

Additional Comments – 11 August 2023

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2.5 Where areas are enclosed by the cemetery fence, but not yet in use for burials, they will be managed by taking an annual hay cut in late July.

So, clearly, the current farm management regime will continue. Councillor King’s assertion that 'there has been a reported decline in the ecological value of the grassland ... in part due to the encroachment of scrub' implies that scrub habitat is of less ecological value than grassland, which is also incorrect. Under the Biodiversity Metric, both the heathland and scrub- Mixed scrub and the Grassland - Other neutral grassland habitats (both identified in the Council’s baseline BNG 3.1 calculation) are given the same Distinctiveness score - Medium. This is because both habitats are considered to be of equal ecological importance.

Additional Comments – 11 August 2023

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Appendix 1 – Statement to DCC A for its postponed meeting on 09

August 2023

22/05714/FB | South Bristol Crematorium And Cemetery Bridgwater Road Bristol BS13 7AS

The proposed cemetery extension into Areas 3 & 4 and the proposed linking drainage associated with these proposals are in an Urban Landscape – Prominent Green Hillside – and within the Colliter’s Brook Site of Nature Conservation Interest (SNCI). These two Local Plan designations are protected by Site Allocations and Development Management Policies DM17 and DM19, which state:

DM17: ‘Proposals which would harm important features such as green hillsides, promontories, ridges, valleys, gorges, areas of substantial tree cover and distinctive manmade landscapes will not be permitted.’ – pages 36/37.

DM19: ‘Development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted.’ – page 40.

The passages from DM19, which the officer quotes in his report – at 10.15 to 10.18 – ignore the express prohibition relating to SNCIs quoted above. This overrides the more generic policy quoted. The prohibitions in both DM17 and DM19 are absolute – ‘will not be permitted’. They are not conditional, nor is the minimum level of harm limited.

The evidence produced by the applicant, including its ecological evidence, shows that the proposed development of these two areas will be harmful: fencing will be erected, drains will be installed, an attenuation pond will be excavated, and, in due course, graves will be dug and those buried there will be visited and, perhaps, memorialised.

We accept that burials may not start in Area 3 for some years and that there are proposals to mitigate this harm. However, harm will still be caused both to the Urban Landscape and to the SNCI, both immediately and in the long term. This is not permitted under DM17 and DM19.

The NPPF at paragraph 179 b) requires that plans should ‘identify and pursue opportunities for securing measurable net gains for biodiversity.’ This is echoed by BCS9, which states: ‘...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 ...’

The applicant’s plans will also result in a net loss of 6.75% of area habitat units. To compensate for this loss, it is proposed to provide offsite BNG in other parts of the SNCI outside the development area. The Council’s ecologist has, in a recent planning appeal (paragraph 7.5, p. 19), advised against seeking to offset lost onsite biodiversity by using an offsite SNCI: ‘Due to its existing level of interest this land [the SNCI] is unsuitable for biodiversity enhancement.' This loss of BNG also amounts to ‘a harmful impact’.

Accordingly, this committee is obliged to refuse this application under the NPPF, BCS9, DM17 & DM19.

We urge the committee to read our previous detailed objections to this application:

1. Preliminary comments.

Additional Comments – 11 August 2023

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2. Further comments.

3. Second tranche of further comments.

I would like to register my objection to the proposed expansion of South BristolCrematorium. Whereas I understand the need for expansion I would seriously question the cost ofthat expansion on both the environment and on Yew Tree farm. The owners of Yew Tree farmhave encountered many problems in the last few years. It is the last remaining working farm inBristol and should be actively encouraged to continue. Losing these 3 fields may well prove to bethe final straw for this farm and for the family that works and sustains it. Has BCC consideredusing other land adjoining or close to the Crematorium? In my view every effort should be made toavoid damaging the Farm, even if this means increased costs. We should not be solely concernedwith money.

Sincerely

Clare Costigan

Commenter Type: Other

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:I would like to register my objection to the proposed expansion of South Bristol

Crematorium. Whereas I understand the need for expansion I would seriously question the cost of

that expansion on both the environment and on Yew Tree farm. The owners of Yew Tree farm

have encountered many problems in the last few years. It is the last remaining working farm in

Bristol and should be actively encouraged to continue. Losing these 3 fields may well prove to be

the final straw for this farm and for the family that works and sustains it. Has BCC considered

using other land adjoining or close to the Crematorium? In my view every effort should be made to

avoid damaging the Farm, even if this means increased costs. We should not be solely concerned

with money.

Sincerely

This is a site of SNCI wildlife importance and the damage this proposal will cause isunacceptable. It goes against the city green spaces motion, our ecological emergency and climateemergency as well as local and national planning policy. - Yew Tree Farm, including this piece ofland, is part of a wildlife corridor that links the city with the surrounding countryside and thereforeshould be protected from any development. It has also been accepted by the Council that thisfarm, the last working farm in the city, should be protected in its present state.There is indeed a shortage of burial ground and this plan is just using a sticking plaster over agaping wound and there needs to be a comprehensive plan for the future of our burial groundsoverall. This is just a temporary measure. I therefore strongly object to this proposal.

I object to the development.I do not agree with this development going ahead.I want to save Yew Tree Farm at all costs.We need to protect this ancient land, which is so very important to our environmental future.Yew Tree farm should remain untouched.

An application of this nature reflects the short sited nature of planning by the council.Clearly this won't be and end of the shortage of ground for burial and merely "kicks the can downthe road". The relevant observations and reports reveal the problems quite clearly and losingwholesale green space of this nature is not only a catastrophic event environmentally but will bereflected in the mental health of the local and city residents. I wonder how much political rhetoricthe electorate will stand before they realise that the planning strategy and the council, as it is, arenot fit for purpose. The trees that will be lost not only serve us as carbon lockers now, but anyreplanting will take at least seventy five years to produce their equal, that does not include the lossof habitat to critically endangered species. This is an application of convenience without seriousthought to the long term welfare of the environment or local residents.

After reading the ecology management plan posted April 11 I'm appalled this applicationis even being considered by Bristol City council. The plan admits significant damage to speciesrich grassland and the SNCI. It's impossible for the crematorium to expand without damaging theSNCI status despite 'best intentions'. The reality is this is destroying one of our last remaininggrasslands in south Bristol to accommodate the dead. The footpaths on this site are incrediblyimportant to the wellbeing of the community. We need to keep our nature sites for futuregenerations to enjoy but turn every field into a literal or ecological graveyard. This wouldcompletely violate the green spaces motion. Passing this would snd the message that democracydoesn't matter to Bristol planning.

Completely unnecessary and harmful to the environment.

This proposal is for the destruction of yet more valuable nature habitat, as is alreadyacknowledged by it's SNCI designation. I absolutely oppose it.

The LANCE Trust was created in spring 2021 by a group of people within Long Ashton& Barrow Gurney concerned about the twin threats of biodiversity loss and climate change withinthese parishes and beyond. Although Bristol City Council, North Somerset Council and variousparish councils had declared both a climate and biodiversity emergency some years before this,the LANCE Trust was created to help turn words into action by working with key stakeholders withan emphasis on maintaining and increasing biodiversity.

We are aware that Britain is one of the most nature-depleted countries in the world and rectifyingthis is vital for many reasons. With the recent disclosure that the present government ignoredrecommendations by its statutory nature advisors to boost biodiversity targets , we are alarmedthat central Government is refusing to acknowledge the severity of the situation. In addition, asurvey has found 7/10 young people are worried about climate change and its effects on theenvironment whilst 86% of people surveyed felt that being outdoors in nature had a positive effecton their mental health. Yet not enough people have access to high quality green and blue space.

Late in 2022, the United Nations Environment Programme (UNEP) wrote "Without protecting andrestoring our ecosystems, we have no chance of achieving the Paris goals, getting to the 1.5Ctarget or buffering the impacts of an already disrupted climate". Early in 2023, theIntergovernmental Panel on Climate Change (IPCC) called "to massively fast-track climate effortsby every country and every sector ... our world needs climate action on all fronts" everything,everywhere, all at once."

In this country, the recent publication of the People's Plan for Nature created by thousands of

people across the country calls for urgent and immediate action from local councils, nationalgovernments, businesses, organisations and communities to protect and fundamentally changehow we value nature.

The Trust understands that the proposed development site in this application forms part of theBristol Green Belt and is within the Colliter's Brook Site of Nature Conservation Interest (SNCI). Itis the Trust's understanding that it also forms an important part of the Bristol, Avon Valleys &Ridges National Character Area 118.From survey data added to many personal observations over the years, the Trust knows that thecurrent farming practices within the development site and adjacent areas are the most nature-friendly of any farm for some considerable distance and, as such, should be considered, valuedand treated as a 'gem' or high quality green and blue space.

We know that, in the last twenty years or so and thanks to the light touch employed by the currenttenant and owner of Yewtree Farm, the ecosystem has benefited enormously with barn owls,kestrels, and buzzards revealing the health of the ecosystem. Important breeding populations ofbull and green finches live within its boundaries, otters in Colliter's Brook and a host of butterflies.As such, this farm provides an invaluable stepping-stone for some species that are able to movebetween Ashton Court & Avon Gorge SSSIs, Tickenham, Nailsea & Kenn Moors SSSI and theChew Valley & Blagdon Lake SSSIs.

Albeit on a small scale, Yewtree Farm showcases how nature-friendly farming can participate inthe much-needed landscape-scale nature recovery projects that lowland England desperatelyneeds.

Taking all this into account, the Trust believes that the importance of this site must not be under-estimated otherwise Bristol and North Somerset will lose a powerful tool in the fight againstbiodiversity loss and, ultimately, the adverse impacts of climate change whilst reducing the accessto much-needed nature that deprived areas within South Bristol so desperately need.The Trust notes that the Council currently has no biodiversity net gain policy (BNG) in the LocalPlan.

The Trust also notes that in June 2021 the House of Commons Environmental Audit Committeestated "the biodiversity net gain policy, in its current form, does not go far enough in contributing tothe transformative change necessary to address biodiversity loss in the UK ... the failure to movetowards a system of net environmental gain risks undermining the government's plans for a greenrecovery and allows developers to focus entirely on biodiversity rather than treat the environmentas a system. This could lead to severe habitat fragmentation."

The Trust would argue that since Central Government has opted for the lesser value of BNGrather than Environmental Net Gain (ENG) one would hope that, at a minimum, the 'gem' that isYewtree Farm will be protected by a requirement to achieve at least 10% BNG in the overall

proposals for the cemetery expansion.

Moving onto one specific area of concern, the Trust is worried by the proposal that an unknownamount of blackthorn and bramble will be removed in order to enhance or restore species-richgrassland areas. These thickets surround the core hedge-line structure and provide habitats formany finches and tits. It is a habitat in increasingly short supply within the surrounding area. Theannouncement by Defra towards the end of March 2023 that there was a 'typo' in the hedgerowtarget originally included in the Environmental Improvement Plan means that the revised targetsare worryingly low compared to the recommendations by the Climate Change Committee (CCC).So, looking to the future, hedgerow habitat such as this is under threat yet delivers so much forboth biodiversity and carbon capture.

The Trust is aware that species-rich grassland is also an important ecosystem that's also underintense pressure but surely it would be better to focus on improving grassland elsewhere awayfrom Yewtree Farm rather than removing invaluable habitat here?The Trust is also concerned with the proposals to remove other thickets bordering Colliter's Brookand close to the railways since these, too, provide protection and habitat for many speciesincluding otters.

The Trust believes that the impacts of biodiversity loss has, within the decision-making process ofboth local and national governments, taken a back seat for far too long.

Surely the time to change this is now within a development by Bristol City Council on Bristol Cityland; and to ensure the viability of Yewtree Farm for all its current and future wildlife resident andmigratory species.

Dear Sir/Madam,

I am writing to express my strong objection to the proposed expansion of the crematorium, whichwould cause significant damage to Bristol's last working farm, an organic farm that plays a vitalrole in providing healthy and sustainable food to the local community. Furthermore, the farm isalso home to a potential new fly species that has been discovered, making it an important site forecological research and conservation.

The proposed expansion of the crematorium would have a detrimental impact on the localenvironment and community.

The preservation of Bristol's last working farm and the potential new fly species should be ofutmost priority for our society. Instead of allowing the expansion of the crematorium, we shouldfocus on protecting our environment and supporting local businesses and organic farms, whichprovide an essential service to the community.

In light of these concerns, I urge you to reconsider the proposed expansion of the crematoriumand take steps to preserve Bristol's last working farm and the potential new fly species. We owe itto ourselves and future generations to protect and preserve the natural world around us.

I would like to express my strong concern about the proposed development plans thatthreaten to destroy Bristol's last working farm. As you are aware, this farm is an integral part ofBristol's cultural heritage, and it provides an important source of organic and sustainable food tothe local community.I understand that the proposed development plans would involve the expansion of thecrematorium on this green space, and this would be in violation of local policies that seek toprotect green spaces. It is essential that we protect our green spaces to promote biodiversity andprovide access to nature for our communities.Moreover, the destruction of the farm would have far-reaching environmental and socialconsequences. The farm plays a significant role in mitigating climate change, providing a habitatfor wildlife, and promoting sustainable agriculture. Losing this farm would be a devastating blow tothe community, and it would result in a loss of local knowledge, culture, and identity.Therefore, I urge you to take action to save Bristol's last working farm and to enforce the localpolicies that protect green spaces. I urge you to reject any development plans that would harm thisvital community asset, and instead, work towards promoting sustainable and environmentallyfriendly development.Thank you for your attention to this matter.

Farm land needs to be left alone for food production. Cremated remains can be interredelsewhere.

I am Appalled that the council are even considering an application that would damageYew Tree farm. The harm this will cause to wildlife goes against the ecological emergency and ourgreen spaces motion. Homes England's lawyer recently pointed out in the Brislington Meadowshearing that BCC is inconsistent with their protection of green spaces and wildlife habitats. This isproving his point. We will have no credibility and will struggle to defend our local plan if BCCcontinue to pick and choose which wildlife habitats they want to protect. I urge the committee toignore the planning officer and refuse this.

There's a potential new fly species here! This is the last place any new developmentshould be going on. That scrub is really important for wildlife. Do you want to be the people thatdestroyed a brand new insect species? Maybe think about that.

Source:https://www.bristolpost.co.uk/news/bristol-news/new-species-grass-fly-unusual-8134565

I objet to the works that make up disrupting Colliters brook SNCI- I have no objection tothe works on the existing site or those outside the SNCIWe have used this land in the family for 60 years and have grazed cattle ensuring a rich and rarebiodiverse habitat, these works will destroy the bullfinch habitat amongst others and I cannot seethat any BNG will be gained.I am concerned about the attenuation pond- an attenuation pond was constructed about 15 yearsago for the Virador site close to this area and locals put fish in it and fished it - small turf warsdeveloped and fights and drinking were prevalent, have you mitigated against this? the woodenfence will not last long, as is the case for the link road fencing.I object to the drainage being discharged into Colliters brook, you have recently granted planningpermission for 500 houses downstream, this is already the most volatile watercourse in NorthSomerset and flooding for Ashton Vale and surrounding areas will be increased.By cutting down the scrub you remove vital and essential cover for our small birds which aredisappearing at an astonishing rate.As farming has to be planned years ahead we may well have to sell or reduce our herd as we willbe excluded from the land for some time. sad times for nature and our small business.

My father is buried in the Muslim section and it is often very muddy. My mother wouldlike to be buried alongside him when her time has come, so the suggested improvements are verywelcome.

PROW BCC/427 runs through Area 4 of the development site containing the proposedattenuation/ detention basin. The plans and documents provided with the application show thePROW running between the basin and the bund created from the arisings from its excavation, 5-10m from the edge of the basin. This is based on an electronic record of PROW which is aninterpretation of the Bristol Definitive Map. The Definitive Map Statement confirms that this PROWis undefined through this area. The exact alignment on the Definitive Map in relation to theproposed basin will therefore need to be established to confirm whether the basin design needsany adjustment so that it respects the PROW legal alignment (to avoid any requirement to legallydivert the route of the PROW if it passes through the footprint of the basin). As the developmentproposal potentially materially effects the alignment of the PROW in this way then this needs to beadvertised as such as part of the planning process.

It is noted that a timber fence will enclose the basin and it is also recommended that safety andwaymarking signage is installed where the PROW runs close to the edge of the basin.

BCC/427 is an unmade field path in character and the PROW Team would not propose that thisfootpath through the site requires general surface improvement. However, where the path crossesinto the development site boundary at both ends (from the gate/ railway underpass to the north-east and hedge gap into the next field at the south-west) the path surface is prone to get verymuddy in wet conditions and it is therefore requested that the developer levels and lays stone atthese points during the construction process, as well as making good any deterioration of the pathsurface caused by the construction work. An alternative option would be to construct a bund forthe PROW to run along.

Consideration needs to be given to public access and safety for users of the PROW duringconstruction work. The following points must be adhered to in order to avoid any legal breachesrelating to the PROW:- The PROW should remain open, unobstructed and safe for public use at all times, other thanwhen temporarily diverted during construction work;- No materials are to be stored or spilled on the surface of the PROW;- There must be no encroachment onto the width of the PROW;- No vehicles are to use the PROW without lawful authority of the landowner(s), unless a privateright of way is shown on property deeds. It is the applicant's responsibility to ensure that theappropriate private right exists or has been acquired from the landowner.- Any scaffolding and/or skips placed over or adjacent to the PROW must not obstruct publicaccess or inconvenience the public in their use of the way and must be properly licensed.Licences can be found online at: www.bristol.gov.uk/highwaylicences- Any damage caused to the surface of the right of way during development works must be madegood to the satisfaction of the Local Highway Authority.- Any interference of the PROW either whilst demolition/construction is in progress or oncompletion, may well constitute a criminal offence.- If construction works are likely to temporarily affect the right of way, a Temporary TrafficRegulation Order (TTRO) will be required to close or divert the PROW for the duration of theworks on the grounds of safety of the public. If you do require a TTRO you must give at least eightweeks' notice prior to the date when you wish to divert/close the PROW to enable the TTRO to beprocessed. Further information on the TTRO application process atwww.bristol.gov.uk/highwaylicences

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to the

city of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

I will support this fully and wholeheartedly as my late mother and husband are buriedhere in the Muslim section.It's always a mission to get there. Myself and my children have to come prepared with decentfootwear as it is hazardous all the time.

The people who have planted plants and borders don't help either and it is a complete hazard andI have tripped many times.

Also it isn't fair as my loved ones graves are as the contact states but most of the graves havenow become personal shrines and are hazardous.

The Muslim committee of the Bristol mosques are aware but they have done nothing to tell theircommunities to stop adding borders and in-fact the sign to inform people to take off their plantsand borders to help the the cemetery workers was taken off.

This also doesn't help as my husbands grave is sinking and the headstone and the grave hasbecome a hazard for us to stand close to it.

I have emailed and many times and have spoken to the people in charge but nothing has beendone.

I suggest first to clean up the graves surrounding area to help the workmen cut the weeds andgrass properly.

I hope this will be heard.

Regards

I believe that an extension to the cemetery is a necessity and will help generations tocome when sadly they have to say goodbye to their loved ones.

There are plans to expand the current South Bristol Cemetery, which includes a newsolution to the drainage problems at the cemetery. The Muslim section is severely impacted by therain water and this application includes a permanant solution to the Muslim Sections problems.I would encourage you all to put in a supporting statement on this application:

https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=RM4E06DNGSS00

A sample response / one which I've sent and you are welcome to use to comment on the linkabove:

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

Kind regards

Mr Khan

Commenter Type: Other

Stance: Customer made comments in support of the Planning Application

Comment Reasons:

Comment:There are plans to expand the current South Bristol Cemetery, which includes a new

solution to the drainage problems at the cemetery. The Muslim section is severely impacted by the

rain water and this application includes a permanant solution to the Muslim Sections problems.

I would encourage you all to put in a supporting statement on this application:

https://pa.bristol.gov.uk/online-

applications/applicationDetails.do?activeTab=makeComment&keyVal=RM4E06DNGSS00

A sample response / one which I've sent and you are welcome to use to comment on the link

above:

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans there

seem to be fair scope for expansion - we support the plan to improve the drainage especially in

the lower end where the Muslim Burial Section is, on regular occasions the graves are

waterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asap

as money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this would

help cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council should

consider its business model and be competitive in the service it provides as well as the price it

charges - the community would appreciate a cap on charges for the coming decade due to the

financial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as well

as space between graves and the headstones are reinforced as well as existing graves marked

and cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignified

burial and ground space for the community at large - we have contributed our heart and sole to the

city of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.

Please keep me posted about this application and it's progress - we feel you should approach all

the major faiths to contribute to this discussion especially the particular faith associated with the

areas of expansion and potential improvements.

In closing we would remind you that:

"The Council has an obligation to provide burial land for residents of Bristol to ensure adequate

burial space is provided for the future that will meet the needs of an increased city population.

Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), this

compares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide new

land would mean that families from across the city or those who have chosen to cremate their

loved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequate

burial land close to the existing site at South Bristol. This site will provide space for different kinds

of burial requirements, including ashes from cremations"

Kind regards

We believe this is a long overdue change and support its completion.

I support the works listed on this proposal and i would recommend the muslim section isdeveloped so that the water drains are sorted and grave which are sinking are restructured as wellas paths and parking is improved for everyone

Hello,

My two sons are buried in this cemetery.. I support this project and request to halo forimprovement

ThanksTahir

I too welcome the plans of expansion to the South Bristol Cemetery, seeing that this hasbeen generously granted-upon the British Muslim community for the past 473 years. For thosewho are unaware it was back in 1550 (16th Century) when Sulieman Noor the first Indian Muslimwas buried here in England at London's St Margaret's Church Westminster. This within itself isrecorded history and evidence for how long Muslims have been here ever-since. So it shouldn'tcome as a surprise when more burial spaces are requested and legally granted. As some willknow my maternal great-grandfather Dr. Bashir Fazel (b. 1885) campaigned for a Muslim sectionto be established in Avonview Cemetery in St George. In time it was eventually acknowledged andby written-fate he was to be buried there in 1965. So for me this expansion for new burial plots isdear to heart and very much relevant. This application has to be accepted in order to avoid andprevent further problems escalating. I say this because I know how it is and how it feels when yourvoice is regretted. I was unsuccessful in achieving the goal for my maintenance/re-letteringfundraising campaign. Only a little amount was raised some knew how important the cause wasbut refused to contribute. You live and you learn and I learned "I am thankful for all of those whosaid "No" to me. It's because of them, I'm doing it myself." A quote by Albert Einstein (GeniusPhysicist, d. 1955). Yet, some are far-sighted and some cannot begin to comprehend importantmatters that need our attention. I thank brother Abdul Raoof Malik for raising his voice on suchcrucial matters and taking up a positive stance. God willing, this time round we will collectively besuccessful.

Pioneer or Pioneers has always been my motto for those Muslims who came long ago andcontributed. Two English Dictionary Definition that stand-out for me are the following:

1) One who goes before, as into the wilderness, preparing the way for others to follow.

2) A person or other entity who is first or among the earliest in any field of inquiry, enterprise, orprogress.

All of what has been defined fits perfectly hand in glove with this dedicated growing community.

Although the above subject matter was just a few set examples, I still felt it was necessary tointroduce it as a opening talking point. The reason being that it brings about greater clarity forthose who are unknown to these contributing factors. Life itself is dynamic and ever-changing, itultimately determines what you consciously attract. I am marvelled at how far Bristol has come interms of diversity of perspectives and ones background.

To elaborate further two state of affairs are worthy of mentioning which I came across time back:

1) It was 'The Charitable and Religious Trust Act, No. 14, 1920', which was passed by the thenBritish-Indian Imperial Legislative Council (1861-1947) on the 20th of March. The act was enactedto provide effective management and supervision over the two institutions. This took placeoverseas in the Indo-Pak subcontinent what was then under British rule. I think this kind of proofhelps bring about change in a positive light, which in turn helps to remind others of this past Actthat was passed with approval.

2) The second demolition of Al-Baqi Cemetery and Mausoleum by the over-zealot orders of KingIbn Saud on the 1st of May, 1925 present-day Saudi Arabia took place. It was the first-everMedinian Muslim Cemetery (established in 622 CE) sacred to both the major sects Sunni andShia. The tract of land had interment graves belonging to the Prophet Muhammad's family andcompanions as well as scholars and historical leaders. All resting in peace over the course ofmany intertwining centuries. It was a British-born English convert by the name of Eldon Rutter whowith great sorrow and agonising pain described or should I say decried the demolition as follows:"All-over the cemetery nothing was to be seen but little indefinite mounds of earth and stones, andbroken rubble of cement and bricks, strewn about." It is referred to and commemorated as the"Day of Sorrow" (Yawn-e Gham) in which this broken-hearted Englishmen comprehended thesites importance and reverence. A universal message of coming together even in such dreadedevents.

Malcolm X (Civil Rights Activist), once said: "Every defeat, every heartbreak, every loss, containsits own seed, its own lesson on how to improve your performance the next time." It is this kind offeeling, steadfastness and understanding in ones commonalty where things are brought about andunderstood. The Prophet Muhammad (Upon whom be peace) himself encourage Muslims to saythe following when visiting the graveyard, what he used to say when visiting Al-Baqi: "Peace beupon you dwellers of these graves of the Muslims and the believers. We will join you when Allahwills. You are our predecessors and we will be your followers. We ask Allah's forgiveness for us

and for you. O' Allah, forgive them and have mercy on them."- Muslim (Hadith). He uttered"Muslims and the believers", which is enough to understand the respect for others.

The Qur'an testifies the same commandment "Those who believe (in the Qu'ran), and those whofollow the Jewish (Scriptures), and the Christians and the Sabians, - any who believe in Allah andthe Last Day, and work righteousness, shall have their reward with their Lord; on them shall be nofear, nor shall they grieve." - Qur'an, Surah Al-Baqarah, 2:62. A similar verse is mention in SurahAl-Maidah, 5:69. English translations used here are by Yusuf Ali also a respected commentator.

I will like to mention an incident that took place in the life of Ali (the Prophet's cousin & son-in-law),which for me was very thought provoking. Something to ponder over and reflect upon for those ofsound intellect and understanding. It is from the sayings of Ali famously known as Nahj ul Balagha(a source respected by both sects Sunni and Shia), No. 121: "Imam Ali was following a funeraland as it was passing along a road, somebody laughed loudly (a sign of discourtesy and lack ofmanner). Hearing this laugh, Imam Ali remarked, "Some of us feel that death is meant foreverybody except themselves or it is destined to others and not themselves or those whom we seedying around us are only travellers going on a journey and will come back to us. It is a sad sight tosee that in one moment we commit them to earth and in the next we hold of the things left by themas if we are going to remain permanently in this world after them. The fact is that we forgetsensible advice given to us and become victim of every calamity."

To concluded death is certain and "Wherever you may be, death will catchup with you, even if youare inside high castles." - Qur'an, Surah Al-Nisa, 4:78. Rich or poor, famous or not, believer ornon-believer, arrogant or humble, white, brown, black or mixed heritage in humanity, messengers,saints and sinners each in their own time have passed. Just like the one who has dedicated histime out to type this or the one who read it from start to end. All-in-all have this one thing incommon and whether it be he or she it will not matter. This reality has existed and will continue toexist it cannot be avoided at any cost. So the least we can do is pay more homage and supportthis effort.

Dedicated to those dearly departed who have someone to remember them by or not in one recentsad case.

With love, renewed hope & god willing success in this endeavour.

Umar Ali Khokhar (Bristolian)

Commenter Type: Other

Stance: Customer made comments in support of the Planning Application

Comment Reasons:

Comment:I too welcome the plans of expansion to the South Bristol Cemetery, seeing that this has

been generously granted-upon the British Muslim community for the past 473 years. For those

who are unaware it was back in 1550 (16th Century) when Sulieman Noor the first Indian Muslim

was buried here in England at London's St Margaret's Church Westminster. This within itself is

recorded history and evidence for how long Muslims have been here ever-since. So it shouldn't

come as a surprise when more burial spaces are requested and legally granted. As some will

know my maternal great-grandfather Dr. Bashir Fazel (b. 1885) campaigned for a Muslim section

to be established in Avonview Cemetery in St George. In time it was eventually acknowledged and

by written-fate he was to be buried there in 1965. So for me this expansion for new burial plots is

dear to heart and very much relevant. This application has to be accepted in order to avoid and

prevent further problems escalating. I say this because I know how it is and how it feels when your

voice is regretted. I was unsuccessful in achieving the goal for my maintenance/re-lettering

fundraising campaign. Only a little amount was raised some knew how important the cause was

but refused to contribute. You live and you learn and I learned "I am thankful for all of those who

said "No" to me. It's because of them, I'm doing it myself." A quote by Albert Einstein (Genius

Physicist, d. 1955). Yet, some are far-sighted and some cannot begin to comprehend important

matters that need our attention. I thank brother Abdul Raoof Malik for raising his voice on such

crucial matters and taking up a positive stance. God willing, this time round we will collectively be

successful.

Pioneer or Pioneers has always been my motto for those Muslims who came long ago and

contributed. Two English Dictionary Definition that stand-out for me are the following:

1) One who goes before, as into the wilderness, preparing the way for others to follow.

2) A person or other entity who is first or among the earliest in any field of inquiry, enterprise, or

progress.

All of what has been defined fits perfectly hand in glove with this dedicated growing community.

Although the above subject matter was just a few set examples, I still felt it was necessary to

introduce it as a opening talking point. The reason being that it brings about greater clarity for

those who are unknown to these contributing factors. Life itself is dynamic and ever-changing, it

ultimately determines what you consciously attract. I am marvelled at how far Bristol has come in

terms of diversity of perspectives and ones background.

To elaborate further two state of affairs are worthy of mentioning which I came across time back:

1) It was 'The Charitable and Religious Trust Act, No. 14, 1920', which was passed by the then

British-Indian Imperial Legislative Council (1861-1947) on the 20th of March. The act was enacted

to provide effective management and supervision over the two institutions. This took place

overseas in the Indo-Pak subcontinent what was then under British rule. I think this kind of proof

helps bring about change in a positive light, which in turn helps to remind others of this past Act

that was passed with approval.

2) The second demolition of Al-Baqi Cemetery and Mausoleum by the over-zealot orders of King

Ibn Saud on the 1st of May, 1925 present-day Saudi Arabia took place. It was the first-ever

Medinian Muslim Cemetery (established in 622 CE) sacred to both the major sects Sunni and

Shia. The tract of land had interment graves belonging to the Prophet Muhammad's family and

companions as well as scholars and historical leaders. All resting in peace over the course of

many intertwining centuries. It was a British-born English convert by the name of Eldon Rutter who

with great sorrow and agonising pain described or should I say decried the demolition as follows:

"All-over the cemetery nothing was to be seen but little indefinite mounds of earth and stones, and

broken rubble of cement and bricks, strewn about." It is referred to and commemorated as the

"Day of Sorrow" (Yawn-e Gham) in which this broken-hearted Englishmen comprehended the

sites importance and reverence. A universal message of coming together even in such dreaded

events.

Malcolm X (Civil Rights Activist), once said: "Every defeat, every heartbreak, every loss, contains

its own seed, its own lesson on how to improve your performance the next time." It is this kind of

feeling, steadfastness and understanding in ones commonalty where things are brought about and

understood. The Prophet Muhammad (Upon whom be peace) himself encourage Muslims to say

the following when visiting the graveyard, what he used to say when visiting Al-Baqi: "Peace be

upon you dwellers of these graves of the Muslims and the believers. We will join you when Allah

wills. You are our predecessors and we will be your followers. We ask Allah's forgiveness for us

and for you. O' Allah, forgive them and have mercy on them."- Muslim (Hadith). He uttered

"Muslims and the believers", which is enough to understand the respect for others.

The Qur'an testifies the same commandment "Those who believe (in the Qu'ran), and those who

follow the Jewish (Scriptures), and the Christians and the Sabians, - any who believe in Allah and

the Last Day, and work righteousness, shall have their reward with their Lord; on them shall be no

fear, nor shall they grieve." - Qur'an, Surah Al-Baqarah, 2:62. A similar verse is mention in Surah

Al-Maidah, 5:69. English translations used here are by Yusuf Ali also a respected commentator.

I will like to mention an incident that took place in the life of Ali (the Prophet's cousin & son-in-law),

which for me was very thought provoking. Something to ponder over and reflect upon for those of

sound intellect and understanding. It is from the sayings of Ali famously known as Nahj ul Balagha

(a source respected by both sects Sunni and Shia), No. 121: "Imam Ali was following a funeral

and as it was passing along a road, somebody laughed loudly (a sign of discourtesy and lack of

manner). Hearing this laugh, Imam Ali remarked, "Some of us feel that death is meant for

everybody except themselves or it is destined to others and not themselves or those whom we see

dying around us are only travellers going on a journey and will come back to us. It is a sad sight to

see that in one moment we commit them to earth and in the next we hold of the things left by them

as if we are going to remain permanently in this world after them. The fact is that we forget

sensible advice given to us and become victim of every calamity."

To concluded death is certain and "Wherever you may be, death will catchup with you, even if you

are inside high castles." - Qur'an, Surah Al-Nisa, 4:78. Rich or poor, famous or not, believer or

non-believer, arrogant or humble, white, brown, black or mixed heritage in humanity, messengers,

saints and sinners each in their own time have passed. Just like the one who has dedicated his

time out to type this or the one who read it from start to end. All-in-all have this one thing in

common and whether it be he or she it will not matter. This reality has existed and will continue to

exist it cannot be avoided at any cost. So the least we can do is pay more homage and support

this effort.

Dedicated to those dearly departed who have someone to remember them by or not in one recent

sad case.

With love, renewed hope & god willing success in this endeavour.

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignified

burial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

Mohammed SajjadResident

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves Collapsedand this is so traumatic for the families.I myself visit my mother and my son's grave and own 2 more plots next to theregraves.197,198,200,201I find myself regularly using a wheel barrow to shovel mud on the graves.I understand some people in the Muslim section are not following cemetery rules that should bemade clear to them and requested to abide by lawn cemetery rules.Hope this work starts asap.

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignified

burial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

There are plans to expand the current South Bristol Cemetery, which includes a newsolution to the drainage problems at the cemetery. The Muslim section is severely impacted by therain water and this application includes a permanant solution to the Muslim Sections problems.I would encourage you all to put in a supporting statement on this application:

https://pa.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=RM4E06DNGSS00

A sample response / one which I've sent and you are welcome to use to comment on the linkabove:

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

Please click on the link and say in comments:

We/I welcome the plans of expansion to the South Bristol Cemetery, looking at the plans thereseem to be fair scope for expansion - we support the plan to improve the drainage especially inthe lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21stCentury.Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

We welcome the plans of expansion to the South Bristol Cemetery, looking at the plansthere seem to be fair scope for expansion - we support the plan to improve the drainage especiallyin the lower end where the Muslim Burial Section is, on regular occasions the graves arewaterlogged and the community is having to use a pump to take away water.

With the cost of the grave rising generally we would appreciate that this work is carried out asapas money should be invested to make the ground safe and better for the next generation.

We would also support an expansion of the Muslim section and the baby burial section - this wouldhelp cater for the many Muslims that are residents of this great city now.

There are now many options for the community to bury their deceased and the council shouldconsider its business model and be competitive in the service it provides as well as the price itcharges - the community would appreciate a cap on charges for the coming decade due to thefinancial circumstances we all face.

With regards to the current Muslim section we would ask that there is adequate drainage as wellas space between graves and the headstones are reinforced as well as existing graves markedand cared for meaning maintained regularly.

Bristol is our home and we are proud of our city - as residents we deserve a good and dignifiedburial and ground space for the community at large - we have contributed our heart and sole to thecity of Bristol - the least it's residents deserve is a burial space that is fit for purpose in the 21st

Century.

Please keep me posted about this application and it's progress - we feel you should approach allthe major faiths to contribute to this discussion especially the particular faith associated with theareas of expansion and potential improvements.

In closing we would remind you that:"The Council has an obligation to provide burial land for residents of Bristol to ensure adequateburial space is provided for the future that will meet the needs of an increased city population.Since 2008 the total population is estimated to have increased by 11.7% (48,600 people), thiscompares to an England and Wales increase of 7.8%

5.2 All the cemeteries in Bristol are close to capacity for new burials and failure to provide newland would mean that families from across the city or those who have chosen to cremate theirloved ones and wish to bury them close to the crematorium would be unable to do so

5.3 In order to deliver additional burial space, land has been identified which will provide adequateburial land close to the existing site at South Bristol. This site will provide space for different kindsof burial requirements, including ashes from cremations"

Absolutely in favour of this project. Long overdue and very much needed for thiscemetery.

The community needs a more desirable area where their loved ones are put to rest inan area they feel is best served for its purpose. Currently the allocated patch is not meeting itsrequirements unless adverse changes are made to resolve the ongoing problems with drainage. Apermanent solution is required as a matter of urgency one that meets the requirements and needsof the decreased.

Expansion of the existing cemetery and crematorium to provide new burial plots withfootpaths and drainage infrastructure.

I highly support this urgent need for a safe muslim burial section where we can bury ourdeceased in the correct religous manner as at the moment we cannot (box surround & coffin) ireally hope you can accommodate us bristol muslims with the space we require to fulfil our lastrights in this world.Many thanks in advance

Working in funeralcare, it is becoming increasingly difficult to provide families withsuitable burial grounds due to lack of space in Bristol cemeteries. I support the expansion of thecurrent south Bristol Cemetery site.

I strongly object to the planning application and I also have concerns over thedestruction of the natural wildlife in the proposed area.Bristol City Council are obligated to protect our wildlife and also our environment.We must ensure our green fields and the climate are protected, for us and future generations.And also avoid any further damage to the land adjoining Yew Tree Farm, and disruption to theiranimals.We have witnessed large gathering over the past few years for funerals, which also impacted thearea's around the entrance to the Cemetery and the adjoining neighborhood.A more appropriate site needs to be looked into that will not have detrimental impact to the area.Similar to that of Westerleigh Crematorium and Cemetery in South Gloucestershire.

I object to the planning application and have concerns over thedestruction of the natural wildlife in the proposed area.Bristol City Council are obligated to protect our wildlife and also ourenvironment.We must ensure our green fields and the climate are protected, for us and future generations.And also avoid any further damage to the land adjoining Yew Tree Farm, and disruption to theiranimals.A more appropriate site needs to be looked into that will not have detrimental impact to the area.

Extra grave space is needed for local families to bury their love ones

As a Trust we object to the planning application and have grave concerns regarding thedestruction of our natural wildlife. Bristol City Councils are obligated to protect our wildlife and theenvironment. Compassion and consideration must be given by every man and woman to ensureour green fields and the climate are also protected. Furthermore, the damage to Yew Tree Farmwill be gone forever. The Trust's members recommends that this application be withdrawn forever.

Yew Tree Farm, including this piece of land, is part of a wildlife corridor that links thecity with the surrounding countryside and there fore should be protected from any development. Ithas also been accepted by the Council that this farm, the last working farm in the city, should beprotected in its present state. I therefore object to this proposal.

This is a site of wildlife importance and the damage this proposal will cause isunacceptable. It goes against the green spaces motion, our ecological emergency and climateemergency as well as local and national planning policy. The damage this will cause Yew TreeFarm is also unacceptable. I strongly recommend withdrawing this application asap because it willnever pass.