‘The planned expansion of the cemetery will have a harmful impact on the adjacent land’

Yew Tree Farm, the last remaining working farm in Bristol, is one of our most important wildlife sites designated as a Site of Nature Conservation Interest (SNCI).

The planned expansion of the cemetery into the farm not only threatens its viability but will also have a harmful impact on the adjacent land also designated as an Urban Landscape.

This is contrary to the Local Plan and to the National Planning Policy Framework (NPPF):

• Development which would have a harmful impact on the nature conservation value of a Site of Nature Conservation Interest will not be permitted. (DM19).
• Proposals which would harm important features such as green hillsides, promontories, ridges, valleys, gorges, areas of substantial tree cover and distinctive manmade landscapes will not be permitted. (DM17)
• If significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused (NPPF, para. 186 a)).

Mark Ashdown is the chair of Bristol Tree Forum – photo Mark Ashdown

Such a development in an ecological emergency should only be considered if there are absolutely no other choices, and yet there are other choices.

Our proposal suggests that harm can be avoided simply by not developing on the SNCI at all.

The One City Ecological strategy, adopted in 2020 and described as a strategy for an ecologically resilient, wildlife-rich Bristol, recognises that nature is one of Bristol’s best assets, and that it is ‘more important than ever to pull together to help nature’.

It encourages us all to confront ecological decline and support our natural spaces.

Yew Tree Farm is Bristol’s last working farm – photo: Mark Ashdown

Whatever solution Friday’s Public health and Communities Policy Committee decides to adopt, it must avoid causing harm to the Colliters Brook SNCI, with its veteran and ancient trees as well as its important hedgerows, rare grassland (a Priority Lowland Calcareous Grassland habitat) and the wildlife that depends on it, especially its dormice.

Unfortunately, neither of the options being considered are able to achieve this. However, there is an alternative solution, as we set out below.

An alternative solution: develop Site 1 without encroaching on the SNCI

It’s said that the current availability of burial sites in Bristol is projected to run out in 2026, so there’s an urgent need for additional burial site provision in Bristol.

We’re told that all this will happen at the South Bristol Cemetery and Crematorium site because no other sites are available.

However, we question the figures used to show how much provision this expansion will create.

South Bristol Cemetery & Crematorium is at the heart of recent controversy surrounding Yew Tree Farm – photo: Emily Brown

We have no objection to burials taking place on Site 1, the land to the south of the cemetery which is outside the Colliters Brook SCNI.

If a modified version of Option 2, one that has no adverse effect on the SNCI, is adopted, there will be sufficient provision for the next decade, enough time to consider additional burial options for the future.

Not only will this satisfy the needs of certain faiths, such as Islam and Judaism, which require interment, but it will also provide a much more suitable and better drained site than has historically been available.

Since drainage capacity for the burial site on Plot 3 would no longer be required, the drainage proposals, including the creation of a rainwater attenuation pond, will have to be redesigned.

Local campaigners have been trying to “Save Yew Tree Farm” for years – photo: Danica Priest

We note that a draft plan for a revised attenuation pond is suggested in Appendix A1 – Further Information document, at page eight. However, this too would have an adverse effect on the SNCI, so other options will need to be explored.

Is it possible to devise a SUDs scheme either somewhere within Site 1, or in the existing cemetery or on land nearby? This should be explored.

This change will require the current grant to be abandoned and a new application submitted, given the significant amendment proposed to enable Option 2 to proceed.

Whether this can be dealt with by way of an amendment seems doubtful, given the significant amendments that would be needed to the design and layout of the site.

Also, the ecological evidence relied on in the original application is now out of date.

Nor does it conform to industry standards for either Preliminary Ecological Appraisal or for Ecological Impact Assessment and will need to be redone.

Furthermore, Natural England is concerned that the rare MG5 and Calcareous grassland on site where a burial ground and the attenuation pond are planned will be destroyed.

After reading the ecological evidence submitted by the Council in support of its application, Natural England observes:

…. our specialist verbally communicated that, based on that survey, it is probable that the SNCI includes some MG5 grassland communities. However, while the report is adequate for assessing cemetery expansion options, we cannot be sure about exact locations and extent of MG5 – that would require a more detailed programme of survey work. We also note that the MAGIC website indicates the SNCI area as containing lowland calcareous grassland Priority Habitat, the evidence cited as being the Bristol Grassland Survey, 1991.

The presence of these habitats alone could justify the site being designated as a Site of Special Scientific Interest. This must be investigated before any further work on the site is allowed.

New biodiversity net gain calculations will also be required and any mitigation proposals will need to include the restoration of the areas of scrub illegally removed last July.

We also note that the dormice survey, promised by this October and required by law, has not been produced in time for this meeting.

Given all this, the Committee must not make any decision until more ecological evidence is available. Instead, it must instruct officers to commission the more detailed programme of survey work advised by Natural England and to halt all further work on the site until this is done.

This is an opinion piece by Mark Ashdown, chair of Bristol Tree Forum.

Main photo: Mark Ashdown

Read next: 

• Bristol leaders: ‘We cannot find another Yew Tree Farm’
• ‘We must balance the need for burial space with protecting the environment’
• Council leader reaffirms Green opposition to development on Yew Tree Farm