Bristol Tree Forum Preliminary Comments 27 February 2023

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3. There are 25 trees on plot 5, all of which will be removed. It is said that tree T50 will be

removed as part of a proposed District Heat Network project. However, as no detail is given

about this and as it is clear to T50 would have to be removed anyway to facilitate this

development, we have included it in our calculations. Please provide information about

the proposed District Heat Network project and how this will be brought forward.

Using Appendix 1 in the Arboricultural Impact Assessment supplied3, we calculate that the

combined canopy area of the trees being removed is 0.0941 hectares and the combined

Urban tree habitat area is 0.1777 hectares4.

4. We calculate that 52 replacement trees will need to be planted in order to comply with

DM17 and BTRS. We doubt that it will be possible to find new replacement planting sites

within a one-mile radius of the restoration site.

5. The applicant has assigned the trees on site to an Other woodland; broadleaved habitat

and ascribed 0.061 hectares habitat area to them. Given the difference between our

measurements above, this habitat area anomaly needs to be explained.

6. In any event, it is clear that the trees on site are an Urban tree habitat under Biodiversity

Metric 3.1 guidance5 and so their habitat area should be calculated based on their combined

RPAs, which is 0.1777 hectares.

7. We note that the applicant’s BNG calculations do not comply with trading rules6. As well

as achieving at least a positive Biodiversity Net Gain (BNG) percentage7, the trading rules

must be complied with. In particular, lost Urban tree habitat should be replaced ‘like for

like’.8

8. The applicant also needs to explain how the Mitigation Hierarchy has been applied and why

it is necessary to remove all the trees from plot 5.9

9. It is notable that the applicant only proposes to enhance existing habitats, four out of five

of which will be enhanced to Good Other neutral grassland habitat. The other will be

improved to Good Mixed shrub habitat. No new habitats are proposed. Again, the habitat

area is less than the restoration red-line areas at 0.16 hectares. Also, some of these

proposals are contrary to the trading rule requirements.

10. Looking at the plans for all the plots, we note that a number of new habitat types are

proposed which have not been factored into the BNG 3.1 calculation – e.g., access steps &

routes, drainage infrastructure, boardwalks and footpaths & a cycleway, seating, a debris

screen, cable runs and access points. Why is this?

11. The applicant has assigned the river to a baseline Other Rivers and Streams habitat which

has High distinctiveness. We disagree. The river passing through plots 1 & 3 is effectively

canalised. It is in a culvert where is passes underground through plot 5.

3 23_00611_FB-ARBORICULTURAL_IMPACT_ASSESSMENT_AND_TREE_PROTECTION_PLAN-3398620 4 Biodiversity Metric 3.1 - User Guide – paragraph 7.9 (p. 74). 5 Biodiversity Metric 3.1 - User Guide – Table 7-1 Urban tree definitions (p. 72). 6 Biodiversity Metric 3.1 - User Guide – paragraph 6.7 (p. 65). 7 Paragraph 179 b) of the National Planning Policy Framework. 8 Biodiversity Metric 3.1 - User Guide – paragraph 7.8 (p. 74). 9 Paragraph 180 a) of the National Planning Policy Framework.

Bristol Tree Forum Preliminary Comments 27 February 2023

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12. Will the Council as applicant commit to achieving at least a 10% biodiversity net gain even

though the relevant parts of the Environment Act 2021 have not yet taken effect?

13. How is it proposed to secure the funding of the long-term 30-year LEMP that will be required

for these habitat improvements?

14. What steps will be taken to ensure that pelagic other riverine species using the river will

be able to access the upper and lower reaches of the Malago, its tributaries and the Avon?

For example, freshwater eels (Anguilla anguilla) are known to be present in the River

Malago and its tributary, Pigeonhouse stream. Freshwater eels are Priority Species under

the UK Post-2010 Biodiversity Framework and are listed as Critically Endangered on the

global IUCN Red List of Threatened Species. Given this, we would expect that, at a

minimum, consideration to be given to the installation of fish passes to enable juvenile and

adult eel migration along the river.

15. Rivers are an inherently a dynamic environment, so cleaning the river in only this stretch

to remove rubbish etc, reprofiling the banks and the stream-bed and removing invasive

non-native species is laudable, but it will be a short-term fix unless ongoing care is taken

of the whole river upstream. It is inevitable that rubbish will continuously be swept

downstream into the restored section, especially during spates. Some rubbish will also be

fly tipped as well as littered dropped into or nearby the river.

16. Accordingly, a key requirement for this project is not just to restore this bit of river but

also to ensure robust arrangements are made for regular cleaning to remove rubbish

(volunteer groups can help with this). Without this, within a few years the river will once

again be an eyesore and fill with metal and plastic objects which will release chemicals

and microplastics into the river. The proposed LEMP will also need to plan for this.

Dear Development Management,

Please provide a copy of the Biodiversity Metric 3.1 calculation upon which23_00611_FB-RIVER_CONDITION_SURVEY_AND_BIODIVERSITY_NET_GAIN__BNG__ASSESSMENT-3398650 (attached) is based on.

Regards

That area is very dense and doesn't have enough trees already, losing more will onlydecline health of the community, river and animals further. Application is not planned thoroughlyand as a person living in the area I object

Trees provide shelter and reduce wind speed, thus reducing heat loss from buildingsduring winter. They provide shade in the summer and evapotranspiration of water from the leaveshas a cooling effect on the surrounding air. This can significantly reduce the need for airconditioning during hot weather. These trees are essential to the health and wellbeing of the areaand as such cannot in anyway be replaced by saplings. Bedminster Green is an essential placelocally even more so now that the level of development is so intense. Removing these trees is, toput it simply, an act of vandalism that will leave the area significantly bereft of essential greencanopy.

Strongly object to the removal of trees. The associated works around Dalby Avenuehave already removed one mature tree outside Catherine's House and the area is quickly beenturned into a concrete jungle. How can you even associate these developments with 'BedminsterGreen' when you're planning on removing aspects of the only green spaces in the area.

Also strongly objecting to the hours of work. Sunday work should not go ahead. The residents ofthis area have already been subject to 1.5 years of road works with another year to go.. How canwe deal with the constant noise and disruption for 7 days a week.

I support the preliminary comments made by the Bristol Tree Forum, and think furtherwork needs to be done to this application in order to guarantee that the approach is suitable forsuch a key part of connective green infrastructure.As pointed out by the Bristol Tree Forum, I do not believe the proposals allocate the correct levelof importance to the green space which is an important feature of Bedminster generally andWindmill Hill in particular.I would like clarification on why there appears to be a discrepancy in the areas of biodiversity thathave been assessed which seems lower than the actual length of the Malago in the plots.Development along Dalby Avenue has begun recently and I am concerned that this has alreadyresulted in a reduction in biodiversity over the plots and contributed to the same in the wider localarea.

It would be a great shame to lose the trees on Bedminster Green. It looks like the proposedreplacemtns are inadequate.Please ensure there is no work on the site on Sundays. Local residents have already been subjectto over a year of road works.

Whilst I am in favour of opening up and restoring the Malago I object strongly to anymore trees being lost. The trees are well loved by the comunity who feel under seige by all theintensive building being done in the small area.

I object on two counts: first trees, second, noise, three stupidity

First the tress. Please do not cut down any more trees in Bedminster. Bedminster is one of theleast biodiverse areas in Bristol and you are taking more of it away. Trees have already beenfelled outside St Catherine's House. In Japan, when there are new developments, they dig thetrees up, protecting the roots as the do so, and plant them elsewhere. Here, we just kill them.Leave the trees of Bedminster Green alone. Do not chop down 14 beloved trees.

Secondly, can we please have consideration for the people that live here. There is so muchdevelopment work going on. It goes on until late at night on weeknights, it starts early on Saturdaymornings and, sometimes, there are works on Sundays. Many complaints have been made to noavail. I work really hard and want my evenings and weekends to be peaceful.

Thirdly, the stupidity. I have lost count of just how many times over the past few years I have hadto come to this portal and object. Not because I am an objectionable person and not because I amopposed to the regeneration of the area but because, with each and every application, I've read itand thought, "are you kidding me?" and "who the hell proposed this ridiculous, ill-conceivednotion?" Just for once. Just once. Could someone, someone, put forward an application that theBedminster residents could look at and go "that would work. That would enhance the area. Thatdoes not destroy our previous habitat" and then either approve it or, even better. Not. Have. To.Comment. At. All.

I am concerned about the plan to remove 14 trees at the green space at bottom ofWindmill Hill between Malago Road and Whitehouse Lane.

My husband and I both support this River Restoration plan.It has the potential to improve the health of residents and local ecosystems.We hope the final details will include how the area will be maintained and by whom.Thank you to BCC officers for thorough work on the plan so far.

This coomment is submitted byThe Windmill Hill and Malalgo Community Planning Group (WHaM)

WHaM supports the preliminary comments made by the Bristol Tree Forum, and think further workneeds to be done to this application in order to guarantee that the approach is suitable for such akey part of connective green infrastructure. We do not believe that the application should bedetermined until this work is done and the local population can be sure that the final proposals areacceptable under planning policy and the implications of those can be spelt out to the localpopulation. Further commentary could be provided once the additional documentation andclarifications called for by the tree forum have been received.

As pointed out by the Bristol Tree Forum, we do not believe the proposals allocate the correctlevel of importance to the green space which is an important feature of Bedminster and WindmillHill. We understand that the green is part of the Parks and Open Spaces network and anImportant Open Space and so should be covered by policies BCS9 and DM17 of the DevelopmentPlan. The River Malago is also protected in the Bristol Development Plan under BCS9 & BCS16.These policies seem to require that the significance of the site be set as High.

We also would likely clarification on why there appears to be a discrepancy in the areas ofbiodiversity that have been assessed which seems lower than the actual length of the Malago, thatruns in the plots.

Existing relationship of the community with the site

The site is well known and liked by local residents. It is a popular stopping off point for familieswith young children in part because of the flowering plants in spring but also because it is ashaded spot with a variety of trees and interesting animals.

The local population is well aware that Bristol has declared a biodiversity crisis, and as such isunderstandably concerned that any proposal affecting green space improves the current situationrather than harms it.

The group is concerned that the other developments planned to the east and west will reduce itssize and as such more must be done to enhance the space's biodiversity and ensure that urbangreen infrastructure with mature trees persists in a way that will be meaningful to futuregenerations.

The group also has received comments that the locals are concerned that there does not appearto be a maintenance plan set up to ensure the river remains in good condition and not left to silt upor become full of refuse affecting flow. One should be provided as part of this application so that itcan be approved as part of the permission.

Existing development impacts and impacts of the proposals

Development along Dalby Avenue has begun recently and the group is concerned that each ofthese already has shown a reduction in biodiversity over the plots and contributed to the same inthe local area. For this reason the green must be enhanced as a paragon of how to improvebiodiversity if the planning committees are willing to sacrifice green infrastructure in the form of:

Removal of trees on the planted car park of the farm federation building (felled early 2023)Loss of trees on little paradise car park for a multi storey replacementLoss of trees around the subway as part of the st Catherine's redevelopmentLoss of green space and shrub planting adjacent to Dalby Avenue as part of the redevelopment ofa tall building

The group is aware that further removals of the existing green infrastructure will occur in the formof the followin

Whilst opening up the Malago could be a positive step in enhancing the biodiversity, of the green,it further reduces the number of trees on the green.

The enhancement with different types of low level planting is also welcome but in order for this tobe effective tree cover also needs to be removed.

The group is also aware that there are bats using the railway line as well as roosting birds usingthe green space. It is keen that these are not disturbed or prevented from using roosts or feedinggrounds.

The group does not support the removal of all trees from plot 5, and was disappointed that someof this has already occurred in the car park of the farm federation building without notice to thelocal residents. As far as the group is aware no permission for the removal of these trees has beensecured, and the application for development of that plot not submitted.

New habitats

It was noted that no reference in the biodiversity net gain calculation was made the stepped areas,boardwalks or cycle ways. Which should also be considered, we assume as new habitat areas,and assigned a level to be reached, why is this

Replacement tree policy

The group does not believe that replacement trees anywhere other than on the site or immediatelyadjacent to it will in any way be acceptable, as they support the biodiversity that lives in that areaand forcing existing occupying animals to compete to survive in less space with fewer resources isunacceptable.

At the current time the group does not believe that these proposals safeguard the future of thegreen as a local hub of green infrastructure and does not support the proposals. It was alsoconcerned that the anomalies in the application should not permit determination.

Broadly I support this development though there are nowhere near enough trulyaffordable homes or social housing included. It's great to open the Malago but unless the Councilis committed to its upkeep it will become quickly another litter strewn , weed choked, clogged upmess, like Colliter's brook often is. The hypocrisy of this Council astounds me, with Nicol Beechsaying in the Southbristolvoice that 'We have declared climate and ecological emergencies,committing to do as much as we can to combat climate change....' yet at the same time grantplanning permission for a High Ropes course in Ashton Court and a massive hosting developmenton Longwell field, both of which will decimate natural wild habitat and its associated wildlife .Despicable. I hope the Green elements of this development don't end in the same farcical way,though I hold out no hope of that.