Your say / Yew Tree Farm
‘It is an assault on our community and planet to lose this site for burials’
Today, mayor Marvin Rees’ cabinet are signing off on the funding to expand South Bristol Cemetery over land currently used by Yew Tree Farm. I tried to submit a public forum statement objecting to this to the council.
Unfortunately, my statement was repeatedly rejected for various reasons despite it being policy compliant and submitted on time. The final reason given was that it didn’t relate to an agenda item despite the cemetery expansion being agenda item 18.
Since the council didn’t appreciate my evidence, I thought I’d share my statement on why expanding the cemetery over Yew Tree Farm would be a bad idea with you all instead.
is needed now More than ever
The species surveys have either expired and are inadequate
The administration claims that ‘extensive’ and ‘robust’ ecological surveys have been done. This is not accurate by any definition of those words.
The species surveys done do not meet the bare min requirements for ecological regulators. All surveys expire after three years and some, like bat and badger surveys expire earlier. Species surveys can not be ‘conditioned’ which means they have to be done before an application is approved.
These are the only dates any surveys occurred:
- June 27 2022
- September 10 2020
- June 12 2020
- June 18 2020
- November 29 2019
Here are just a few of the many examples where the ecological surveys fall short:
No winter bird survey was done, no doormice or harvest mice surveys were done and these are protected species. Nest tubes are ideally sampled at intervals across the active season with May, August and September being key months for survey.
To do an invertebrate survey you need to visit five times during different parts of the same year. This was not done.
Bats hibernate during winter months (November-March). January and February is a key period for hibernation roost surveys. No surveys were done during those months.
A survey for breeding birds would normally require multiple visits (min three days) between April and June/July. This was not done.
Objectively, this application did not have the required information to make a decision on the impact on protected species so it should have been refused.
Sources:
- www.gov.uk/guidance/protected-species-how-to-review-planning-applications
- cieem.net/wp-content/uploads/2019/04/Advice-Note.pdf
- cieem.net/resource/uk-bat-mitigation-guidelines-2023
- www.ecologybydesign.co.uk/ecology-surveys-calendar
South Bristol Cemetery and Crematorium has been granted permission to expand onto land used by neighbouring Yew Tree Farm – photo: Martin Booth
Ecological mitigation is unreliable
An award winning study published in the British Ecological Society in 2021 found that the majority of ecological mitigation measures were not reliable or based on evidence.
I highly recommend reading this study in full when you have time but here is a summary for now:
“We found that, of the 446 species mitigation measures we identified in total, real-world evidence on the effectiveness of those measures had been gathered on less than half of them…
“This paints a worrying picture of the ability of current ecological mitigation practice to compensate for the impacts of development and thus halt species declines in the context of rapid development.”
The truth is while it looks good on paper most mitigation doesn’t work in practice. Offsetting was meant to be a last resort not common practice. If we keep moving nature when it’s inconvenient for development we won’t have any left.
Sources:
- besjournals.onlinelibrary.wiley.com/doi/full/10.1002/2688-8319.12089
- www.imperial.ac.uk/news/235860/cep-student-wins-georgina-mace-prize/
Biodiversity net gain is very new
Biodiversity net gain (BNG) is so new it’s not even mandatory yet. We just don’t have the years of evidence based data to rely on it. Its benefit for replacing existing wildlife has not been proven.
BNG is meant for increasing biodiversity on sites with little to no nature present, it’s not supposed to be used as a way to justify harm to established ecosystems. We can’t let an irreplaceable site like Yew Tree Farm be our BNG guinea pig.
Avon Wildlife Trust objects
Avon Wildlife Trust objects to this proposal and they don’t object to things lightly. In the past three years they have only objected to three other applications/allocations: Western Slopes, Brislington Meadows and the Redrow section of Yew Tree Farm.
This should be all the evidence you need that this application must be withdrawn.
It was incredibly inappropriate for Bristol City Council’s chief planning officer, Simone Wilding, to claim during the planning committee meeting that Avon Wildlife trust didn’t fully understand what they were objecting to.
Planning officers are supposed to be impartial and planning is a quasi-judicial process. Simone had no right to speak for the respected charity.
Avon Wildlife Trust issued a statement after the meeting to confirm Wilding was incorrect in her assumptions: “In response to our objection, the Head of Planning questioned to what extent Avon Wildlife Trust had looked in detail at the proposal. Specifically, because we had mentioned further threats to the site in addition to the crematorium expansion.
“When looking at threats to habitats, you have to consider it holistically and assess the cumulative impact from developments on all areas of the site. We are shocked to see these cumulative impacts, and our concerns, dismissed when considering developments to SNCIs.
“We know the site very well having visited over many years and know the long-standing value that this site offers to wildlife with its meadows, scrub and ancient hedgerows.’
Sources:
Planning officers have a history of being wrong about this site
The same planning officers who are swearing that this is the only option for burial space and that no harm will come to Yew Tree Farm or the SNCI also swore they didn’t need planning permission at all!
They told us all this was a done deal and that they had a lawful right to develop. They were wrong about this and had to withdraw their application.
If it wasn’t for Bristol Tree Forum challenging officers, the lawful development certificate would have been approved by the officers themselves.
There is therefore a precedent of these officers being wrong about this site. They were proven to be wrong about not needing planning permission and now they are wrong about the harm caused to the SNCI status.
This will put all Sites of Nature Conservation Interest (SNCIs) at risk
Interpretation of local planning policy DM19 to allow “harm” if there is BNG and/or mitigation will open up every SNCI to development, especially those being taken out of our local plan like Redrow site and Western Slopes/Novers Hill.
This is especially true since the local plan still needs to be approved by a planning inspector.
Developers including Lovell and Homes England have already left comments on the draft local plan saying they intend to fight the council to include development on our beloved nature sites with SNCI status. We can’t let this happen.
Sources:
- www.bristol.gov.uk/files/documents/6456-2023-03-21-bcc-local-plan-review-further-consultation-summary-report-final-with-cover-accessible
- www.bristoltreeforum.org/wp-content/uploads/2023/12/Sth-Bristol-Cemetery-Blog.pdf
Yew Tree Farm in Bedminster Down is Bristol’s last working farm – photo: Mark Ashdown
The mitigation proposals for soil preservation are unrealistic, unviable and unenforceable
The soil preservation requirements needed to maintain SNCI status are unrealistic and expensive to enforce.
‘3.1 When graves are dug, handle soils with care: remove and stack turf; remove and store topsoil and subsoil separately; return soils and turfs appropriately; and avoid excessive compaction.’
Two separate experts have been consulted to give their opinion on the practicality of this mitigation proposal and both have said the same thing. While technically it’s possible in theory, on this site its never going to happen.
Here is a direct quote from a real gravedigger: “When there are headstones or kerb sets, the soil dug out can’t go back because of the footings. Plus, when you put human remains like ashes or bodies in the ground, it changes the soil.”
He also mentioned that expecting grave diggers to put the soil back exactly as it was is unlikely. Even if they promise to do it, how can you check? And by the time you figure it out, it’s already too late.
Banning memorials is an equalities issue
In the first committee meeting for this application, a big deal was made about burial space being an equalities issue. There were also comments made about providing a safe space for the bereaved community.
However one of the conditions in the ecological mitigation proposal document is:
‘3.4 Restrict memorialisation to a small stone and a container for flowers. Explain rationale to plot holders and remove any surplus material.’
How will this be explained to grieving visitors who are not plot holders but visiting lost loved ones?
Will grieving families have to tell everyone they know that you can’t leave anything if you are visiting their grave?
If a family loses a child and left a plastic toy as a memorial would the crematorium staff really take it away?
This leads to a situation where the staff have to either upset grieving families or the SNCI will be damaged. That’s a horrible position to be in and it’s most likely that the SNCI will be the loser in this scenario.
Banning plastic memorials is cruel to grieving families and difficult to enforce. It throws the equalities argument out the window.
This goes against our nature commitments
Yew Tree Farm is ‘low hanging fruit’ for our commitment to preserve 30 per cent of our land for nature.
We should be looking to help get it to SSSI status, not turning it into a graveyard and mitigating damages.
An independent ecologist that surveyed part of Yew Tree Farm mentioned that the site is only a few species away from qualifying as an SSSI and if not disturbed could reach that in a year or two.
This won’t ever happen if the crematorium expansion plan goes ahead.
We can compromise
There is a compromise where everyone wins.
This application could be withdrawn and the council can submit a new one for just the non-Yew Tree Farm site. That way we have burial provision for the next five to ten years and we don’t have to damage the farm.
Then efforts can be made to fully explore alternative sites like Elsbert Drive in Bishopsworth or sites in north Bristol. It makes far more sense to find a site that doesn’t require a £1.7m drainage pond.
You can’t undo the destruction of the SNCI once it happens. You can’t un-dig the drainage pond and bring the wildlife and trees back to life.
If officers are wrong and this mitigation doesn’t work, you can’t take that back!
Green spaces motion
In September 2021, full council passed a motion unanimously that protects Yew Tree Farm specifically. Ignoring this motion as this application does, is anti-democratic.
The exact wording of the motion is:
“Full Council resolves:
Council calls for 1. To call for a halt to the proposed redevelopment of or incursion into any remaining productive wildlife rich agricultural land.”
Note it says halt any incursion- objectively this application is an incursion.
Let’s not forget that access to nature is an equalities issue and south Bristol has some of the most deprived areas of the city.
Those of us supporting the farm are not a loud minority group as some politicians like to claim. We are south Bristol. We are the majority.
Yew Tree Farm SNCI is universally supported, not only by local residents but by wildlife experts, environmentalists, farmers and sustainable food organisations.
It would be an assault on our community and planet to lose this site for burials.
I know this statement is long but it’s very important. Thank you to all those that got this far.
I hope the cabinet will make the right decision and refuse funding for the South Bristol Cemetery expansion over Yew Tree Farm but sadly I know they won’t.
Some cabinet members showed up and took their picture next to the ‘Save Yew Tree Farm’ banner over the summer.
Now, months later, when they are asked to act on that “cast iron” commitment, their support is nowhere to be found.
This is an opinion piece by Danica Priest, an environmental campaigner and Green Party candidate for Filwood ward in May’s local elections
Danica Priest at Yew Tree Farm – photo: Danica Priest
Main photo: Rob Browne
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