BTF Comments – 19 February 2025

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2. Irreplaceable habitat

One tree, Ref. No. 6041, a Field maple, is a veteran and three others are Notable (Ref. Nos. 6012, 6037 and 6042). Veteran trees are irreplaceable and protected under NPPF December 2024, paragraph 193 (c). In line with accepted practice, the Root Protection Areas (RPA) of these trees and the Pedunculate Oak (Ref. No. 6020) should be based on a multiplier of 15 x stem diameter.

The applicant has also identified a number of trees on the development site that are protected by a Tree Preservation Order (TPO).3 These trees have not been identified in the applicant’s arboricultural evidence. This needs to be done.

There are also lines of TPO trees along the Bath Road and Scotland Lane boundaries of the site. It is unclear whether any of these trees will be impacted by these proposals. This needs to be investigated. A copy of these three TPOs needs to be published on the planning portal.

3. Biodiversity Net Gain – the baseline habitats

Save for the issues discussed below, we have adopted the applicant’s biodiversity net gain evidence. We do not discuss the Watercourse habitats.

a) None of the trees identified in the applicant’s arboricultural evidence have been included in the baseline biodiversity survey. Taken as a whole, these trees, which are classified as Individual trees habitat, cover a habitat area of 7.1084 hectares, of which 4.7754 hectares will be retained. We have assessed this habitat as being in good condition - they meet condition assessment criteria A, B, C (54 of the 95 tree records are listed as mature), D & F.

b) One tree - Ref. No. 6041 - is a veteran Field maple and should have been identified as Irreplaceable habitat. Whilst the Metric calculation must record this habitat as part of the baseline survey, separate, bespoke provision must be made to address the potential impact of any activity which may cause the deterioration of this irreplaceable tree.

c) The applicant has ignored its own arboricultural evidence and underestimated the extent of the baseline Woodland and forest habitat on the site. Using the woodland identified in the arboricultural evidence, the correct area of this habitat should be recorded as 1.2569 hectares, of which 0.0991 will be retained. We accept that this habitat is in poor condition.

d) We note that the applicant has identified much of the habitat on the site as Heathland and shrub - Mixed scrub (4.0225 ha). This includes the woodland habitat identified in the arboricultural evidence. The UK habitat classification, version 2,4 defines h Heathland and shrub as vegetation with a >25% cover of dwarf shrub that are <1.5 metres high or woody species <= 5 metres high. The shortest woodland height identified in the arboricultural evidence is 6 metres. Accordingly, none of this habitat should be classified as Heathland

3 APPENDIX_5.1_LANDSCAPE_AND_VISUAL_IMPACT_ASSESSMENT_PART_1-3742078 – Image EDP 3.1. 4 https://www.ukhab.org/.

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and shrub - Mixed scrub. We have discounted the woodland habitat area from the Heathland and shrub - Mixed scrub area used.

e) The applicant has ignored its own arboricultural evidence and underestimated the extent of the baseline linear hedgerow habitats – 0.295 kilometres (k) of Species-rich native hedgerow. We calculate that there is 1.0550k of Species-rich native hedgerow, of which 0.9891k will be retained and 0.03k will be enhanced (FAC Ref. No. HR6002, HR6005, HR6006, HR6008, HR6010, HR6011, HR6016). There is also 0.5931k of Native hedgerow habitat, all of which will be retained (FAC Ref. No. HR6003, HR6004, HR6007, HR6009, HR6012, HR6013, HR6014, HR6015). Only one hedgerow (FAC Ref. No. HR6001) can reasonably be identified as Mixed scrub habitat. We accept that all these habitats are in good condition.

f) When the historic maps published on Know Your Place5 are examined, it is clear that most of the hedgerows on site have been in existence since at least the production of the 1840s Tithe maps. As a result they should be classified as historically important under the Hedgerow Regulations 1997 (the Regulations).6 In addition, all the hedgerows which contain five or more woody species (FAC Ref. No. HR6002, HR6005, HR6006, HR6008, HR6010, HR6011, HR6016) are also likely to be ecologically important under the Regulations. All the hedgerows are also Priority habitat.7

g) With the adoption of the Local Nature Recovery Strategy (LNRS) by the West of England Mayoral Combined Authority last November,8 of which Bristol City council is a member, all baseline habitats must be classified as having low strategic significance. The same applies to created and enhanced habitats that are not in one of the designated areas or one of the priority habitats identified. As only the riparian border running along the stream on the southern boundary of the site is identified in the LNRS, all other habitats outside this area must also be designated as of low strategic significance.

Based on the above, these proposals will result in the following net losses of biodiversity:

a) Area habitat: -32.74%; a shortfall of 67.60 habitat units. b) Hedgerow habitat: -0.02%; a shortfall of 1.62 habitat units.

There are also the following trading rules shortfalls which will need to be addressed:

a) Grassland - Other neutral grassland – 25.55 habitat units. b) Heathland and shrub - Mixed scrub – 4.68 habitat units. c) Individual trees - Urban tree – 25.82 habitat units. d) Woodland and forest - Other woodland; broadleaved – 4.63 habitat units. e) Species-rich native hedgerow – 0.79 habitat units.

All these habitats have moderate distinctiveness and may only be replaced by the same broad habitat type or a habitat type with a higher distinctiveness. We assume that these 61.47 habitat

5 https://maps.bristol.gov.uk/kyp/ 6 https://www.legislation.gov.uk/uksi/1997/1160/contents. 7 https://www.gov.uk/government/publications/habitats-and-species-of-principal-importance-in-england 8 https://www.westofengland-ca.gov.uk/what-we-do/environment/the-local-nature-recovery-strategy/.

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units will be provided through offsite mitigation. There are currently no registered Biodiversity Gain Sites within the LPA and only one within the Bristol, Avon Valley National Character Area (NCA) (BGS-2811240019), which is some seven miles away in the Bath and North-East Somerset LPA. Failing that, replacement habitat will have to be exported to a BGS much farther afield while the result Bristol’s biodiversity becomes further degraded. Our analysis shows that the average distance been the site of the habitat loss and where it is mitigated offsite is currently some 61 miles.10

4. The Green Belt

The site is within the Green Belt and does not fall within any of the exemptions set out in NPPF. Nor are there any very special circumstances which would justify the harm which these proposals will cause. Very special circumstances will not exist unless the potential harm to the Green Belt - by reason of inappropriateness or any other harm resulting from the proposal - is clearly outweighed by other considerations.

The site is unlikely to fall within the new definition of Grey Belt as it is pristine farmland that has never been developed. Grey belt is defined as:

For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.

Purposes (a), (b), or (d) in paragraph 143 are:

a) to check the unrestricted sprawl of large built-up areas

b) to prevent neighbouring towns merging into one another

d) to preserve the setting and special character of historic towns.

However, if the emerging local plan is adopted and the site is removed from the Green Belt, this will no longer be an impediment, as it is proposed under policy DS12 that this land will be released from the existing Green Belt and allocated for housing development. It remains uncertain, even with the impending public examination phase about to open, that the current examination of the proposed Local Plan will be found to be sound.11

A copy of our BTRS and BNG calculations can be made available on request.

9 https://environment.data.gov.uk/biodiversity-net-gain/search/BGS-281124001 10 https://bristoltreeforum.org/2025/01/25/replacing-lost-biodiversity-a-missed-opportunity-for-local-offsetting/ 11 https://www.bristol.gov.uk/residents/planning-and-building-regulations/planning-policy-and-guidance/local-

plan/local-plan-review/local-plan-examination

Emergency access is proposed onto Stockwood Road to the south of the site, we wouldlike to know how this will operate, specifically how unauthorised use will be mitigated, this will beparticularly relevant to mopeds/motorcycles which already present a significant issue in borderingareas. Plus how regular cars can be prevented from using it as a no doubt main escape route fromwhat is already a clogged up A4.

A one way traffic system outside Scotland House Farm will simply not work as we need to be ableto access our property to get in and also get out of the property. If we are to enter stationery trafficwaiting at lights how does that work? We would block the flow of traffic trying to get into ourproperty too and you cant put traffic lights on our entrance

We object to the lane being used for trucks, machinery and years of construction traffic that willadd to the danger on this already accident prone road. Children walk down this road to go homeafter school and college to Stockwood through the rugby club. Abusing this small lane would bevery dangerous.

We can currently see no other properties from the front and side windows of our own property. It'sone of the reasons that we moved here, it's quiet and beautiful on the edge of greenbelt. Weobject most strongly to using greenbelt to build homes in an already densely populated and underresourced area of Bristol. The A4 is a car park at rush hour, the junction at Stockwood Road and

the A4 is so busy that cars are backed down the lane and along Hungerford Road. How will theinfrastructure cope with so many more cars, and no more schools or doctors??

We object to houses being built at an elevation that will cause a lack of privacy to our properties.We will be overlooked and our current green view will be all windows and roofs.

What about all the wildlife that we know is in the fields there. The bats that live in the trees, thefoxes, rabbits, deer and many more... all pay us regular visits and its part of living in thecountryside. This development will eradicate them and bring crime - see the police report that thisdevelopment WILL bring nuisance and crime to and area that currently has none because itsgreenbelt!

Commenter Type: Neighbour

Stance: Customer objects to the Planning Application

Comment Reasons:

Comment:Dear Planning Committee,

I write with deep and serious concerns regarding the proposed development, particularly with

reference to the border along Stockwood Road opposite Scotland House Farm. This ill-conceived

plan threatens not only our cherished way of life but also the very essence of what makes our

community special.

Preservation of Green Belt and Wildlife

The proposed development on our precious green belt land is nothing short outrageous. This area

is a haven for diverse wildlife, including bats, foxes, rabbits, and deer, which grace us with their

presence regularly. To bulldoze their habitat would be an irreversible tragedy, robbing future

generations of the joy of living alongside nature. Moreover, the police report indicating that this

development will bring crime and nuisance to our currently peaceful area is deeply troubling.

Traffic and Safety Concerns

The proposed changes to Stockwood Road are not just inconvenient; they're downright

dangerous. The suggested single-lane carriageway with traffic lights or priority system is a recipe

for disaster. As we informed Bellway at consultation, as did several other neighbours. It would

create:

- Serious access issues for Scotland House Farm residents

- Increased noise and pollution from queuing and accelerating vehicles

- Unsafe conditions for horses in the stables and sheep in nearby fields due to heightened

pollution

- Chaos during the regular Old Reds' tournaments and festivals

The idea of an emergency access point onto Stockwood Road raises serious questions about

unauthorized use, particularly by mopeds and motorcycles, which are already a significant issue in

bordering areas.

Infrastructure Strain

The A4 near here is already a virtual parking lot during rush hour, with the junction at Stockwood

Road notorious for being one of the worst in Bristol. Queues back up into neighbouring roads

during rush-hour already. How can our already strained infrastructure possibly cope with the influx

of new residents? The lack of additional schools and medical facilities is a glaring oversight that

will undoubtedly lead to further strain on our community resources.

Privacy and Character of the Area

The proposed buildings, situated too close to Scotland House Farm, threaten to destroy the

privacy and rural character that drew many of us to this area. We appreciate that the buildings

have been slightly lowered on the plan after our concerns, but they are still too high and the

potential for overlooking gardens is unacceptable. We implore you to consider setting the buildings

back further from the Stockwood Road boundary and reducing their height further to preserve the

unique character of our neighbourhood.

Construction and Long-term Access Issues

The proposal for construction access via Stockwood Road is both dangerous and disruptive. This

road is already treacherous, with a history of accidents, several fatal. Introducing heavy

construction traffic would only exacerbate these risks. Furthermore, the long-term implications for

residents' daily lives - from bin collections to oil deliveries and horse trailer access - have not been

adequately addressed.

In conclusion, I urge the Planning Committee to reject this proposal. It threatens our safety, our

environment, and our way of life. If this development has to take place (we hope not), then we

would suggest

1. A walkway from the proposed site via the Park and Ride and over a zebra crossing to the

school instead of the traffic light system which is completely unworkable. This was suggested at

consultation.

2. No access via Stockwood Road/Scotland Lane for building lorries, or for emergency access.

This was suggested at consultation.

3. Properties close to Stockwood Road to be lower in height and much further back from the road.

This was suggested at consultation.

I write with deep and serious concerns regarding the proposed development,particularly with reference to the border along Stockwood Road opposite Scotland House Farm.This ill-conceived plan threatens not only our cherished way of life but also the very essence ofwhat makes our community special.

Preservation of Green Belt and WildlifeThe proposed development on our precious green belt land is nothing short outrageous. This areais a haven for diverse wildlife, including bats, foxes, rabbits, and deer, which grace us with theirpresence regularly. To bulldoze their habitat would be an irreversible tragedy, robbing futuregenerations of the joy of living alongside nature. Moreover, the police report indicating that thisdevelopment will bring crime and nuisance to our currently peaceful area is deeply troubling.

Traffic and Safety ConcernsThe proposed changes to Stockwood Road are not just inconvenient; they're downrightdangerous. The suggested single-lane carriageway with traffic lights or priority system is a recipefor disaster. As we informed Bellway at consultation, as did several other neighbours. It wouldcreate:- Serious access issues for Scotland House Farm residents- Increased noise and pollution from queuing and accelerating vehicles- Unsafe conditions for horses in the stables and sheep in nearby fields due to heightened

pollution- Chaos during the regular Old Reds' tournaments and festivalsThe idea of an emergency access point onto Stockwood Road raises serious questions aboutunauthorized use, particularly by mopeds and motorcycles, which are already a significant issue inbordering areas.

Infrastructure StrainThe A4 near here is already a virtual parking lot during rush hour, with the junction at StockwoodRoad notorious for being one of the worst in Bristol. Queues back up into neighbouring roadsduring rush-hour already. How can our already strained infrastructure possibly cope with the influxof new residents? The lack of additional schools and medical facilities is a glaring oversight thatwill undoubtedly lead to further strain on our community resources.

Privacy and Character of the AreaThe proposed buildings, situated too close to Scotland House Farm, threaten to destroy theprivacy and rural character that drew many of us to this area. We appreciate that the buildingshave been slightly lowered on the plan after our concerns, but they are still too high and thepotential for overlooking gardens is unacceptable. We implore you to consider setting the buildingsback further from the Stockwood Road boundary and reducing their height further to preserve theunique character of our neighbourhood.

Construction and Long-term Access IssuesThe proposal for construction access via Stockwood Road is both dangerous and disruptive. Thisroad is already treacherous, with a history of accidents, several fatal. Introducing heavyconstruction traffic would only exacerbate these risks. Furthermore, the long-term implications forresidents' daily lives - from bin collections to oil deliveries and horse trailer access - have not beenadequately addressed.

In conclusion, I urge the Planning Committee to reject this proposal. It threatens our safety, ourenvironment, and our way of life. If this development has to take place (we hope not), then wewould suggest1. A walkway from the proposed site via the Park and Ride and over a zebra crossing to theschool instead of the traffic light system which is completely unworkable. This was suggested atconsultation.2. No access via Stockwood Road/Scotland Lane for building lorries, or for emergency access.This was suggested at consultation.3. Properties close to Stockwood Road to be lower in height and much further back from the road.This was suggested at consultation.

Do not support this planning permission due the traffic congestion for Bath road andlack of infrastructure within the local area.

I'm concerned about traffic along the A4. At peak hours the traffic is already at astandstill. With 500 new homes and therefore 500-1000 extra cars using the road, what will bedone to improve the flow of traffic?

I refer to the proposed plan specifically along Stockwood Road opposite ScotlandHouse Farm. The buildings on the plans are too close to Scotland House Farm, and specificallythe The Long Barn and currently it appears the garden could be overlooked from the highbuildings. The proposed buildings should be set back further from the Stockwood Road boundaryto prevent this. The proposed buildings should also be reduced in height.The rural character of Stockwood Lane would also be impacted by the proposed development.There should be no access to the development from Stockwood road. Access to the site wouldcreate unnecessary dirt and traffic in an already treacherous road and corner. This road iscurrently used as a cut through to Stockwood. Heavy traffic including works trucks would no doubtcause many road accidents. Even without a proposed access route to the development near thecorner of Scotland House Farm we are witness to constant, sometimes fatal, car accidents.The proposed single Lane carriageway along Stockwood Road would create huge problems forScotland House Farm residents getting in and out of the Scotland House Farm gates.

I refer to the proposed plan specifically along Stockwood Road opposite ScotlandHouse Farm. The buildings on the plans are too close to Scotland House Farm, and specificallythe The Long Barn and currently it appears the garden could be overlooked from the highbuildings. The proposed buildings should be set back further from the Stockwood Road boundaryto prevent this. The proposed buildings should also be reduced in height.The rural character of Stockwood Lane would also be impacted by the proposed development.There should be no access to the development from Stockwood road. Access to the site wouldcreate unnecessary dirt and traffic in an already treacherous road and corner. This road iscurrently used as a cut through to Stockwood. Heavy traffic including works trucks would no doubtcause many road accidents. Even without a proposed access route to the development near thecorner of Scotland House Farm we are witness to constant, sometimes fatal, car accidents.The proposed single Lane carriageway along Stockwood Road would create huge problems forScotland House Farm residents getting in and out of the Scotland House Farm gates.

1. Detrimental impact upon The Granary's residential amenities.

The new development does not compliment and respect the character and amenities of theneighbouring properties at Scotland House Ferm by not taking into consideration the density,design, height and landscaping of the development to reduce the impact on and enjoyment of ourproperty.

2. Loss of privacy and overlooking of The Granary

The proposed development overlooks the primary amenities areas of our garden and house as theproperty is built back to front. Our main garden, raised decking area including hot tub, orangeryand our main bedroom that has a full picture window and Juliet balcony would be severelyoverlooked from the rooms that are two storey level and above in the new development resultingin serious invasion of our privacy.

The site overlooks our stables and land which also will also be seriously overlooked and impactedby the development from the rooms that are two storey level and above.

Bellway themselves within their planning application have identified our property with a smallnumber of others as one which will be severely impacted by this development.

Under the Human Rights Act Art 1 states that a person has the right to peaceful enjoyment of alltheir possessions which includes the home and other land. We believe that the proposeddevelopment would have a dominating impact on us and our right to quiet enjoyment of ourproperty. Art 8 states that a person has the substantive right to respect for their private, family lifeand surroundings which this development does not provide us.

3. Community engagement by Bellway and the two storey zone.

We were identified by Bellway as a property which was severely impacted by their development. Arepresentative of Bellway and Meeting Place did visit our property, took photos and listened to ourconcerns especially as the development would be substantially looking over our property and land.We were advised that Bellway would send an architect and member of their planning team to workwith us to address our concerns. This meeting was never organised by Bellway and instead wewere presented with a revised site illustration of the the development which reduced the first line ofhousing running from The Long Barn to Old Reds Rugby Club entrance to two storeys high andset back further with a greenbelt and landscaping. This illustration raised additional questionswhich were asked of Bellway and we were told that they would be answered by the outlineplanning application.

However what has been proposed in this planning application appears to differ to the revised siteillustration provided to us by Bellway as the submitted documents shows a significant reduction inthe area to be designated as the two storey zone compared to the illustration and the questionsraised by us to Bellway about this area are hard to establish from the 86 accompanyingdocuments.

4. Proposals to make Stockwood Road/Scotland Lane single carriageway and to have a estateemergency access road on to Stockwood Road

Bellway have advised that they plan to put a cycle track and footpath along the lane which willreduce the road to single carriageway outside our property. Bellway have advised us they proposeto make this part of the lane traffic light controlled or priority to traffic one way over another runningalong the boundary of our property and land. We strongly object to this as it will create accessissues in to and out of Scotland House Farm, create additional noise and pollution from queuing /accelerating traffic and vehicles going over the raised tables especially at commuting times andweekends during the rugby season or when Old Reds hold tournaments/festivals at the ground.

Our only means of access to our property would become unsafe and inconvenient. The proposalwould adversely affect the amenities and access of the existing residential properties in ScotlandHouse Farm. For example, how would weekly bin collections, oil deliveries, septic tank cleaning,hay and feed deliveries and getting a horse trailer in and out of the properties be achieved withreduced turning space in and out of the properties and safely against the traffic flow when waiting

for electric gates to open to access the properties.

There should be no access to the development both during and after construction througnStockwood Road/Scotland Lane. Access to the development would create unnecessary noise, dirtand traffic on an already hazardous road. Adding additional heavy traffic including works truckswould no doubt cause additional traffic / pedestrian accidents.

This application No. 24/03186/P lodged on 19th.August relates to a significant housebuilding proposal along the Bath Road at Brislington and immediately adjacent to thePark and Ride facility at Stockwood Lane.

This land is greenbelt. If development were to be allowed here then Bristol andKeynsham will be in danger of being joined together and on any count this must not beallowed to happen.

If the provision of the Park and Ride is regarded as a precedent for development on thisland then some history should be taken into account. What happened there is that asubstantial amount of hardcore was put down to provide hard standing for a possiblyprivately owned parking area. This was blatantly illegal but had the effect of making thearea unsuitable for agricultural use; to convert it into an official Park and Ride wasmaybe an inspired solution but this should in no way open the door to buildingdevelopment along the Bath Road.

Yours sincerely,

The site is highly suitable for a mixed use development. However, I would encouragesegregated cycle paths instead of mixed use paths wherever possible. I also believe there couldbe an extra storey or two at the properties at the denser part of the site closer to Bath Road. Thiswould increase the amount of new homes and increase the viability of the new local centre.