The road width and parking spaces do not account for vans being parked there, whichbased on the surrounding estate is significant in number.Access for the emergency services in narrowed roads means there is little clearance of vehicles atthe junctions, with poor turning circles of certain vehicle types which are the cheaper platforms toconstruct an ambulance(Renault/Fiat). There is also concern that there is an expectation thatpeople will travel at speeds less than 20mph, so visibility at junctions can be reduced. As aresident on the St Giles estate can clarify that is a rare occasion, that cars travel less than 20mphso higher speeds need to be assumed in the plan.The lack of parking for 2 vehicles per property - particularly the houses (one of which should becalculated van size, and the 2nd a car size within the grounds of the properties - as opposed to theindustry standard of 1.6 vehicles per dwelling - as has been applied in this plan), it will result inunlawful/ dangerous parking that severely restricts emergency access.As a recently retired paramedic I will cite Paxton Drive- Ashton Gate - where there are inadequatenumber of spaces for the occupied dwellings, and parking has numerously prevented me gettingto a property when on an emergency call.I believe all the houses need parking within its boundary and walkway not occluded if van in situ.this would minimise on road parking which more often though negligent parking obstructsemergency vehicles gaining access quickly.

BTF HMMP Comments – 30 April 2024

2

a) Preliminary Ecological Assessment (PEA) Report, Johns Associates Ltd, September 2023

(also J01198 Hengrove Park Phase One PEA Report, 26 September 2023).

b) J01202 Hengrove Park, Reptile Survey Report, Johns Associates Ltd, December 2023

c) J01202 Hengrove Park, Bat Activity Survey Report, Johns Associates Ltd, December

2023

d) J01198 Hengrove Park Phase One 4.0 V1.

e) J01198 Condition Assessment Sheets (Hengrove Park Phase One PEA Report, Appendix

C.

f) Drawing J01198-P1-02 baseline UKHab Classification.

g) J01161 Culverhayes Care Home BNG Assessment Report (included in error?).

6. It is not clear if the pre-construction proposals at section 3.1 relate only to those parts of

the site where construction will take place.

7. There is not indication whether the habitat creation and enhancement work proposed to

those parts of the site where construction will not take place, e.g. the eastern section of

the development site, commence – will take place before, during or after the construction

phase?

8. The term ‘undesirable species’ at section 3.4.4 needs to be defined.

9. It is unclear if fallen leaves under trees be retained or removed – see 3.4.7, Autumn

Clearance and 3.4.8, Arisings.

The Biodiversity Gain Plan, Appendix B

10. Section 19 states: 'Where possible, all habitats of higher ‘distinctiveness’ have been

retained.' These habitats have not been identified. What does this mean?

11. Section 19 also states: ' Individual Trees: Several trees removed. Others are retained and

protected, in line with Root Protection Areas. Tree removal is compensated with woodland

planting and tree planting.’

Individual trees habitat which has been removed may not be compensated with woodland

planting (the creation of Woodland and forest habitat) if this involves creating Woodland

and forest - Other woodland; broadleaved habitat or any other broad Woodland and forest

habitat of the same medium distinctiveness.

This is contrary of the biodiversity gain trading rules which require that losses of medium

distinctiveness habitat ‘must be replaced by area habitat units of either medium band

habitats within the same broad habitat type or, any habitat from a higher band from any

broad habitat type.’6 Woodland and forest - Other woodland; broadleaved habitat is a

medium distinctiveness belonging to a different broad habitat type to the Individual trees

6 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-_User_Guide_.pdf - page 13.

BTF HMMP Comments – 30 April 2024

3

broad habitat.

12. Section 21. Why are the on-site enhancements not considered significant? 3.215 hectares

of the 9.15 hectares of baseline habitats (some 35%) are proposed to be enhanced.

13. The response section 27 is incorrect. The Statutory Biodiversity Metric has not been used

as section 28 attests.

14. The responses given at sections 36, 37 & 38 are out of date.

15. Section G, Off-site habitat enhancements. Our calculations show a shortfall of 1.91 habitat

units of Woodland and forest - Other woodland; broadleaved habitat. It is likely that this

will need to be mitigated offsite to achieve both the minimum 10% biodiversity target and

comply with the trading rules.

Generally

16. We note that the development of Hengrove Park still elicits significant feeling from local

residents who value the park as a local amenity for a number of recreational and leisure

purposes. We question whether those proposals for creating and enhancing the biodiversity

in around those parts of the development on the eastern section of the site are realistic,

given that they will remain open to free access by the community and pets.

17. In particular, we note that there are no proposals to protect slow worms or hibernating

reptiles, amphibians and hedgehogs or bats in bat boxes from potential conflict with visitors

and their pets.

18. We are concerned about the potential health and safety and habitat degradation

implications of leaving the wetland areas open access. We doubt that ‘regular annual

ecological inspections to remove litter and debris’ will be sufficient.

BTF Comments – 13 December 2023

2

replacement trees of an appropriate species should be provided.

The applicant has failed to demonstrate that the proposed removal of trees is essential to allow for appropriate development.

This loss alone is unacceptable and indeed unnecessary, for sustainable development. If the aim of sustainable development across the city is to increase space for nature, including increased tree cover, as is the aspiration laid out in the One City plan, the Ecological Emergency

Strategy, and the UN’s Sustainable Development goals, loss of green infrastructure at this scale must be avoided.

It also runs counter to the Council’s declarations of climate and ecological emergencies and ignores its unanimous 7 September 2021 resolution to protect Bristol’s Green Belt and its Green Spaces.

However, if the planning authority concludes, notwithstanding all this, that the removal of these trees is essential, then 163 replacement trees will need to be planted to replace the trees lost. As the applicant proposes planting 203 trees onsite, there will be no requirement for offsite replacement planting.

The biodiversity metric calculation

The applicant has agreed to increase the baseline habitat biodiversity found onsite by at least 10%. Using Biodiversity Metric 4.0 (BNG 4.0), the applicant calculates that its proposals will achieve a net gain of 21.66% of area habitat and 3,908.30% of hedgerow habitat.

We take issue with the area habitat calculation for the following reasons:

We do not agree that the applicant has chosen to treat the majority of the trees on site as part

of a Woodland and forest habitat – Other woodland; broadleaved. They have allowed for only 0.1873 ha of Urban Individual trees habitat and assigned the remaining trees to 2.442 ha to the Woodland and forest habitat. Here is their breakdown of each of these habitats:

Whilst Area 8 in the south of the site (0.99 ha) might legitimately be designated Woodland and forest habitat, we say that, given that all the remaining trees are growing either separately or in groups in an urban park and were planted as part of the parkland setting, they should be designated Urban Individual tree habitat.

Whilst we accept that the applicant was correct to undertake its biodiversity metric calculation

BTF Comments – 13 December 2023

3

using BNG 4.0, we have used the new Statutory biodiversity metric (SBNG). It was published on 29 November last and will become obligatory when the biodiversity net gain elements of the Environment Act 2021 come into force in January 2024. Notwithstanding this, the result from this calculation is almost identical to that generated by BNG 4.0, save that BNG 4.0 only uses three size categories when calculating the area of Urban Individual trees habitat, whereas SBNG uses four. Our analysis below is based on the SBNG guidance.

Defining woodland and forest habitat

The Metric Guide does not define Woodland and forest habitat. However, the UK Habitat Classification, UKHab, upon which the Metric is based, defines it, as ‘Land with 25% or more cover of trees that are five metres or more in height.’ This definition doesn’t mention the minimum land area required.

The Food and Agriculture Organization of the United Nations Global Forest Resources Assessment 2020, defines forest as:

‘Land spanning more than 0.5 hectares with trees higher than 5 meters and a canopy cover of more than 10 percent, or trees able to reach these thresholds in situ. It does not include land that is predominantly under agricultural or urban land use.’

As far as we are aware, this useful definition is not used in the UK.

The habitat area of Woodland and forest habitats is based on its total measured canopy area.

Defining individual trees habitat

The Metric Guide defines the ‘Individual trees’ habitat as one where the tree is:

• an individual or part of a group

• over 7.5cm in diameter at breast height (DBH).

Individual trees habitats are classed as ‘urban’ or ‘rural’, depending on the degree of urbanisation of habitats around the tree. If they occur within a habitat characterised by the presence of trees, such as woodland, orchard or wood-pasture and parkland, they should not be recorded as Individual trees habitat.

The habitat area of Individual trees habitat uses set values to represent the area of trees

depending on their diameter at breast height (DBH). This value is a representation of canopy biomass and is based on the root protection area (RPA) formula derived from BS 5837:2012.

This table sets out the class sizes of Individual trees and their habitat area equivalent:

BTF Comments – 13 December 2023

4

This approach places a higher value on the areas of all but the largest Individual trees habitats than if they formed part of a Woodland and forest habitat.

In this case - including only the trees growing onsite plus the two, partially offsite groups – G19 & G20 - which will be removed as a result of these proposals - we calculate that the baseline area of the trees, when categorised as Urban Individual trees habitat, is 6.4209 ha of which 0.1625 ha will be removed and 6.2421 ha will be retained. This is 4.78 ha more than the

applicant’s calculation.

We have also assessed the trees surveyed as being in Moderate condition, not Poor as the applicant asserts. This is because they meet three of the six criteria required for Individual trees habitats – B, D & F. As a result, the applicant’s proposal to enhance this habitat to Moderate is not applicable so we have excluded this from our calculation.

This area and condition difference has a significant impact on the final biodiversity net gain calculation, valuing these baseline habitats at 63.60 Habitat Units as opposed to the applicant’s 12.11.

Because Urban Individual trees habitat is excluded from the overall habitat area calculation, we have increased the baseline Modified grassland habitat to 1.616 ha and its Enhanced area to 1.3619 ha to compensate for this change and retain the 9.15 ha onsite habitat area.

We have also substituted the proposed 0.748 ha of Woodland and forest habitat being created for an equivalent area of Individual trees habitat – 184 Small category trees – and adjusted the Other neutral grassland habitat from 0.021 ha to 0.92 ha to compensate for this change.

These changes reduce the projected area habitat biodiversity net gain from 21.66% to 8.01% - a shortfall of 1.93 area habitat units and nearly 2% below the applicant’s minimum 10% BNG target. Here are the Headline Results:

BTF Comments – 13 December 2023

5

Miscellany

1. Our calculations have identified a breach of Rule 1 of the SBNG (and BNG 4.0) which must be followed.

The trading rules set minimum habitat creation and enhancement requirements to compensate for specific habitat losses, up to the point of no net loss. They are based on the habitat type and distinctiveness of the lost habitat. As the trading rules do not apply beyond no net loss for the shortfall habitats, the applicant’s calculation will need to be adjusted to comply with Rule 1 to avoid any net loss of these habitats or by replacing them with higher distinctiveness ones.

This table shows the shortfalls after the loss of the Low Distinctiveness habitats have been

mitigated:

BTF Comments – 13 December 2023

6

2. We share the Nature Conservation Officer’s scepticism2 about the viability of creating a very high distinctiveness habitat - Wetland: Fens (upland and lowland). We also question the viability of creating wetland habitats in what is, and will increasingly become, a popular and much-visited park as the local population grows and the demand for accessible green spaces grows.

It is notable that both Metric calculators (BNG 4.0 & SBNG) recognise this by assigning a

20-year time-to-target to achieving the target condition and setting the standard difficulty of the creation and the final difficulty of the creation to High, resulting in only 0.72 habitat units being delivered.

3. We also share the Nature Conservation Officer’s concerns about whether the calculation of the tree habitat being lost has taken the creation of the footpaths and other user facilities proposed into account.

4. We agree that a long-term habitat management plan must be submitted before this application can be considered.

A copy of our Statutory BNG Calculation can be downloaded here.

2 23_02376_M-ECOLOGY_OFFICER_COMMENTS-3519615

I am pleased to see such a well thought out and designed site which is so desperatelyneeded in the current housing crisis in Bristol. Goarm Homes have thought this out well with theirteam, not only does it bring a decent amount of afforadable housing to a city with 20k people onthe waiting list for social housing but it also embraces the need for sustainable energy and thenecessary use of modern methods of constrcution.

I am aware that people often will have objections to housing being built in areas like this whenthere is a loss of green space but we are in a total housing crisis both in terms of number but alsoin affordability.

With an additional number of 1.1k people and families in temporary accommodation, children (likemy grown up daughter) having to leave Bristol as housing is unaffrodable for those in lower paidwork and businesses in bristol struggling to recruit as the workforce is priced out we desperatelyneed well thought out schemes like this.

We are past the stage where if we want a functioning city we can cling to the 'nice to have' inareas and underutilised space and need to accept that we need more schemes like this for thefuture of our children and the city.

Dear Angelo, Having now read the NCO's comments (attached for those cc'd to this email who may not yet have seen it), we have decided to delay submitting our detailed comments as they are largely covered by the NCO's report. We await sight of the applicant's response to these. However, a number of other issues arise as a result of this report: 1. We note that the PEA states that a schedule of trees to be removed has not yet

appropriate habitat type given the mix of trees here. 5. It is indicated that the Line of trees habitat in the B-1 On-Site Hedge Baseline tab

will be enhanced, yet no proposed enhancement calculation is provided. Please clarify this.

6. Looking at the proposed whole-site post-development habitats (see below), it would appear that there will be a significant deterioration in the quality of the wildlife corridor from the north of the site, particularly from the Mounds to the north-west. Can the NCO please be asked to comment on this.

I look forward to hearing from you. In the meantime, please publish a redacted version of this email on the planning portal." Regards Mark CD Ashdown Chair - Bristol Tree Forum

Ward Councillor Statement on Hengrove Park Reserved Matters - 23/02376/M

As can be seen from comments submitted from residents, the development of Hengrove Park stillelicits significant feeling from local residents who value the park as a local amenity for a number ofrecreational and leisure purposes. Whilst we accept that development of Hengrove Park will goahead, we want to make a number of points in relation to this application and the wider plans forthe development:

Density of Development

We note that Goram Homes has decided to reduce the number and density of homes built inPhase 1 as detailed in this application. Although there is a planning condition stating that the entiresite should have a build density of 66 dwellings per hectare - a condition that applies to the site asa whole - this application will only be 21.7dph overall, and 56.5dph for the residential area.

We note comments that it is intended that more central phases should be built more densely butare concerned about the impact this phase-by-phase may have - we do not want to see the laterphases having to shoe-horn in increased density to meet the condition in the outline planningapproval.

It is our position that this phase could have been developed at a higher density, and that if it hadbeen, this would have provided more flexibility when future phases are developed (in the absence

of a masterplan, as noted below). We would like to see full details of planned densities across allphases in order to be reassured that this condition can be met without compromising public spacewithin the development.

Community Space, the Residual Park, and Open Spaces

We particularly do not want to see the density target met by sacrificing either community space,the residual park, or other open spaces; we consider these to be sacrosanct. Further, any car-parking or other amenities associated with the proposed community buildings should not be at theexpense of parkland or open space.

We will therefore be keeping a watching brief on developments to ensure that the public spaceprovided for in the Outline Permission - and in particular the green space - does not get eroded.

For the avoidance of doubt, this includes any land that it is proposed will be fenced off for the useof individual groups - e.g. in the development of the replacement Scout Hut. If additional land isrequired (over and above the footprint of the existing hut), and that will not be available for publicuse, then this should not be at the expense of the requirement for a park and other open spaces.

Lack of Masterpan

We are disappointed that there is, as yet, no masterplan for the whole area allowing for the currentapplication to be viewed in context. We appreciate that work is being progressed on this, but feelthat this would have aided members of the committee in their deliberations as well as helpinginform public comments.

As well as helping answer the above concerns over development densities in each phase, andprovision of the new park and green spaces, this would also help with understanding how thephases will relate to each other, and the neighbouring areas, a number have also undergone, orare due to undergo, significant development.

Relationship with neighbouring sites

Immediately adjacent to the wider site is Hengrove Play Park, a Strategic Play Facility for childrenfrom across South Bristol (and beyond) - development of future phases must not compromise thisamenity which will also face challenges associated with the development of the neighbouringleisure park site, not least as the city is about to invest a significant sum of money in updating thefacilities.

Trees and Ecological Assessments

We have been copied into a significant amount of correspondence relating to the ecological

impacts of the development. Regretfully these have generally been one-way generating morequestions than answers. We believe that the applicants should be meeting their requirements toprotect and/or enhance the natural environment of the site, and to mitigate any loss of currenthabitat as per local and national planning policy and the outline planning conditions.

Cllr Andrew BrownCllr Sarah ClassickCllr Tim Kent

There is not the infrastructure in the area to support this level of housing so I object tothe plans in full

As with many others the concern is infrastructure, which was not set up for so manynew residents, there have been a number of increases of late, yet no inmprovement / investmentin the infrastructure.It appears to be expected that new residents will not have cars, children or medical requirements.I feel improvements / additions need to be made before residential buildings.

thousands of the members of the community use the park, by foot or cycle, in transit and forrecreation. Removing trees and shrub and fundamentally changing the use of the wooded areasreferred to here as ‘park’ will affect the community’s use of this space.

A further concern is the lack of car parking, and a lack of allocated spaces, in the housingdevelopment. Parking is a severe problem in the wider community surrounding the developmentwith insufficient space for vehicles off-road as it is, and adding more housing with insufficientcapacity for car parking will make road safety worse with more parked cars on the surroundingstreets. I am pleased to see a reasonable proportion of cycle parking provided, although it would bebetter to provide secure cycle lockers for the flats, than communal spaces which are not as secure.And I am pleased to see the presence of EV chargers, but the specification and security of these hasnot been identified (how will they be charged if not connected to a particular house or apartmentand if not secured for the development, has the developer considered other people from thecommunity may wish to use the facilities, taking up resident parking space?)

I note that the ‘Belvedere Tower’ appears to overlie a culvert of an Ordinary Watercourse tributary tothe Brislington Brook. It is a shame that the opportunity to open up this culvert is not being taken.

Kind regards

I object to this application in full. The area should be left as it is, it is an area used bydog walkers and a very successful car boot. The local schools are already over subscribed and itis extremely difficult, if not impossible to get an appointment at the health centre. There havealready been a lot of other housing developments in this area and every one of them have beenapproved. The roads and infrastructure cannot support a development of this size and I do not feelany of the above has been taken into consideration

We object to houses being built on this area. The Hengrove fields are used daily by dogwalkers, children, runners, people playing sports and the car boot sale. It is full of wildlife as wellas a used area for the local community. The local area is short on facilities Drs, schools, transportas it is. The traffic caused by the additional houses will bring Whitchurch/Hengrove to a standstill.Parking is already a problem in the area and will be made worse with all the extra houses.

I object to houses being built on this area. The Hengrove fields are used daily by dogwalkers, children, runners, people playing sports and the car boot sale. It is full of wildlife as wellas a used area for the local community. The local area is short on facilities Drs, schools, transportas it is. The traffic caused by the additional houses will bring Whitchurch/Hengrove to a standstill.Parking is already a problem in the area and will be made worse with all the extra houses. Whynot build more schools, doctors and dentist before building accommodation. Our area is short ongreen space as it is. Just leave it alone and let everybody enjoy the space to play

We have already fed back that the plans are excessive but this doesn't seem to betaken on board.

Our schools and doctors are already over subscribed, traffic is horrendous and the amount of carsbeing parked all along the side of the roads is getting ridiculous. Adding 1435 extra homes,alongside the god knows how many homes that have recently been built in the area will causechaos. What are your plans to tackle this? You only care about meeting housing quotas but don'tconsider the infrastructure at all in any of your plans.

I am sick of reading about plans to 'improve the plot of land' when the local community are happywith it in its current state - we do not want you to build on it! Ive lived in Whitchurch my whole lifeand am strongly considering moving out of the area as the council seem hell bent on destroying it.Why don't you build else where instead of cramming everything into one tiny area?

There is already insufficient infrastructure to support the existing residents in theWhitchurch/hengrove area. Schools are over subscribed, there is only one doctors surgery for theentire area which is impossible to get in to. To build these additional homes on an area of land thatis used by local residents is unsustainable and impractical.

We just don't want the building work or the 200 extra houses in this area where we havelovely greenery. This is where the rugby club plays and our children and dogs play. This is beingruined and demolished to line someones pocket and put an eye sore where a nice place used tobe. Filled with potentially 400 additional people taking up places in local school and making trafficand our local shops chaos.The area was nice and you are about to ruin it with another council estate.This is to line others pockets and is ruining Bristol and the area.Noone wants this !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

It's all very well asking for our say but it is never taken into account - your minds aremade up about what you are building on that land, whether we like it or not.

You are building on every little scrap of land you can get your hands on in the local area and can'tseem to sell what you've already built (E.g houses on airport road). Our doctors are oversubscribed, roads congested but you will not listen and think you know best. I can guarantee if youwere to do a referendum in this area to ask if they would like this land built on, the answer wouldbe no. You do not care about the impact on local people let alone the negative effect on localwildlife.

You have received feedback time and time again about the excessive plans but still you continueto ignore us and plan to build more houses, without the supporting infrastructure. You changedthis area to brown belt land, simply to get your hands on it, which is corrupt in itself and shouldnever have been allowed.. and then ask for our opinions on something we don't want!!

This area is used by so many people for dog walks, for a mental health break, an open space forgames, exercise ..but you think building on it and including a tiny scrap of parkland is acceptable.If you think having parkland is important you wouldn't build there in the first place.

It was one of the only civil airports open during ww2 (alongside one in Liverpool). The site is rich inhistory but that clearly means nothing to the council, just so long as you meet your housingquotas!

Whitchurch used to be a lovely area but you are absolutely destroying it. Not to mention the otherplans in the surrounding areas such as a permanent traveller site and tower block flats at Broadwalk, which again no one wants but you'll find a way to proceed with (even after initial rejections!!)

I object to these plans and any building on green land/park land!