This application is flawed in that there is no BNG calculation despite the intention to fellall four of the only trees on the site and most of the existing open ground is proposed to besurfaced.The loss of a large domestic building primarily to provide on site car parking at a time of acutehousing crisis shows a lack sensitivity in an organisation proposing a facility which would requirethis quality.The need for on site car parking is questionable when other nurseries within the area are able tooperate very successfully with no on site car parking. The site is within the proposed South BristolLiveable Neighbourhood Area so car use harks back to a previous era for local journeys.Locally recruited staff would not be looking for car parking space and users would find a drop offfor ebikes preferable to having to negotiate unnecessarily increased vehicle traffic.This proposal needs to take far more account of the time we live in rather than the profligate agethat we need to escape from.

Looking forward to seeing this conversion, the plans look great and it will be a greataddition to the community.

Preliminary Comments – 09 July 2024

2

mitigated, or, as a last resort, compensated for, then planning permission should be refused.’2

Avoidance of harm should always be the first consideration. This has been expressly echoed in the recently published biodiversity gain hierarchy, which makes ‘avoiding adverse effects of the development’ the first priority, especially when medium distinctiveness habitats such as Urban Individual trees are being considered for removal.3

If this is not possible, then the lost biodiversity must be replaced and at least 10% more created.

The lost biodiversity replacement

Under the Statutory Metric Guidelines,4 these four trees are Urban Individual trees habitat and should have been included in the applicant’s biodiversity metric baseline calculation. This has not been done.

Using the arboricultural evidence provided, we calculate that this Urban Individual trees habitat has a combined habitat area of 0.0408 hectares (see Figure 2).5 We have assumed that this habitat is in poor condition and has a high Strategic Value (trees are expressly protected in the Local Plan by policies BCS9 and SADMP DM17).

Tree ID

Common Name

Tree Count

Trees Removed DBH

(cm)

Statutory Metric

Category

Baseline Habitat

Habitat Retained

(ha)

Habitat removed

(ha)

Totals 0.0408 0.0000 0.0408 4 4

T1 Rowan 1 1 37 Medium 0.0163 0.0000 0.0163

T2 Himalayan birch 1 1 40 Medium 0.0163 0.0000 0.0163

T3 Goat willow 1 1 24 Small 0.0041 0.0000 0.0041

T4 Sycamore 1 1 12 Small 0.0041 0.0000 0.0041

T5 Sycamore

Offsite T6 Sycamore

T7 Common lime T1

of TPO 1390

Figure 2: Statutory Metric - Urban Individual Trees habitat area calculation.

There is a disparity between the number of proposed post-development trees to be planted: the biodiversity gain calculation states 11, whereas 16 new trees are identified in the arboricultural evidence6 and the Proposed Ground Floor and Block Plans,7 as well in the BNG

2 https://assets.publishing.service.gov.uk/media/65a11af7e8f5ec000f1f8c46/NPPF_December_2023.pdf. 3 https://www.legislation.gov.uk/uksi/2015/595/part/7A - Article 37A. 4 https://assets.publishing.service.gov.uk/media/65c60e0514b83c000ca715f3/The_Statutory_Biodiversity_Metric_-

_User_Guide_.pdf. 5 We have treated tree T4 as an onsite tree for convenience, even though, strictly speaking it is offsite. 6 24_02234_F-ARBORICULTURAL_IMPACT_ASSESSMENT___TREE_PROTECTION_PLAN-3699297. 7 24_02234_F-PROPOSED_GROUND_FLOOR_PLAN-3699339 24_02234_F-PROPOSED_BLOCK_PLAN-3699337.

Preliminary Comments – 09 July 2024

3

Calculation Existing and Proposed Site Finishes8 documents.

If 11 ‘small’ category trees are planted, they will create an area of 0.0448 ha, yet the applicant’s calculation shows an area of 0.06 ha being created. This appears to be based on the 12 trees (one of which is ‘medium’ sized) shown in the Tree Helper on the Main Menu tab. This creates a total habitat area of 0.0611 ha.

These anomalies will need to be resolved.

Furthermore, the Statutory Metric Guide assumes that post-development Individual trees habitat creation will be based on planting ‘small’ sized trees, unless the applicant can show compelling evidence that larger trees are proposed.9 No such evidence has been produced.

We have adopted all the other baseline and created habitats and parameters used by the applicant.

Conclusion

In the first instance, the trees on site should be retained if at all possible. If this is not possible then their loss must be compensated.

If the missing baseline Urban Individual trees habitat is factored into the applicant’s biodiversity gain calculation and 11 post-development ‘small’ category trees are planted to achieve moderate condition with high strategic significance, then these proposals will only achieve a net gain of 2.60%, less than the 10% the applicant plans for and is obliged to achieve. There will also be a breach of the trading rules because there will be a shortfall of 0.03 habitat units of Urban Individual trees habitat, which must be replaced with the same broad habitat or with habitat with a higher distinctiveness.

If 16 trees are to be planted using these same parameters, then a net gain of 24.44% will be achieved and the trading rules will be met. However, we question whether, given the size of the site, this is overstocking. We need to see a list of the tree species proposed to be planted.

We agree that, under SADMP DM17 and BTRS, nine replacement trees will be required, all of which will be provided on site.

We invite the applicant to recast its biodiversity gain calculations to take account of the issues raised above. Until this is done, we are, regretfully, unable to support this application.

We note in passing that the applicant’s biodiversity gain calculation has been produced as a .pdf document. Not only is this out of logical order but it makes analysis of the calculation very hard to test. We urge the applicant to produce its next iteration in the Defra approved MS Excel format.

8 24_02234_F-BNG_CALCULATION_-_EXISTING___PROPOSED_SITE_FINISHES-3699348. 9 Page 55 of the Statutory Metric Guide.

I am massively in support for this, I think it is brilliant to turn this lovely building intosomething of practical use and prevent it from being derelict.

However my only concern as a resident on dean lane is the parking. By no means do I want tomake a complaint however as someone who has received two parking tickets this year due to thefact I haven't been able to park my car outside the front of my house on dean lane in the morningsdue to parents of the school taking up all available spaces I feel this will become more of aproblem. Due to location of the parking zones and one side of the street being classified assouthville and the other bedminster, it can often cause issues.

May I suggest that the permits of residents who live on dean lane apply to both bedminster andsouthville zones and therefore increase the availability of parking options