In October, Leicester City Council put in a planning application to cut down 21 trees in St George's Churchyard in the Cultural Quarter (near Curve). They say that the trees make the churchyard gloomy and encourage anti-social behaviour. However, St George's Churchyard is right next to the ring road, where the levels of air pollution exceed legal limits.
Last autumn, when this planning application was first discussed, we put up diffusion tubes to measure NO2 levels in the churchyard and nearby. We found that the air in the churchyard was cleaner than the air in a nearby street, a similar distance from the ring road, suggesting that the trees are protecting local residents from dangerous levels of air pollution. Mature trees also support wildlife and give us all access to nature, both of which are desperately needed in the middle of the city.
Leicester Friends of the Earth therefore objected to the planning application and encouraged individuals to send in a short version of our objection, to help convince the Council to reject the planning application. Our letters are below. We are now waiting for the decision...
Suggested text for individual responses
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Dear Mr. Ipgrave,
I am writing to object to the planning application for St George's Churchyard on the following grounds:
Air pollution
Leicester Friends of the Earth’s monitoring data shows that the trees in St George’s Churchyard seem to be absorbing pollution and thereby protecting local residents from the serious health effects of breathing dirty air. I am concerned that removing 21 trees would increase the level of pollution in the area, potentially exposing people to illegal levels of air pollution.
Biodiversity
Mature trees provide an important wildlife habitat and help to keep the urban area cool. The City Council’s own planning guidance acknowledges this. Mature trees cannot be replaced by saplings. Furthermore, there is already a shortage of green space in the centre of the city. The Council should not cut down any trees without a very good reason.
Anti-social behaviour
The planning application states that the trees should be removed to combat anti-social behaviour but that is nonsensical. If local authorities cut down a tree in every place where they received a complaint of anti-social behaviour, there would soon be no trees left and the air would be unbreathable. Moreover, research has shown that green space reduces anti-social behaviour and is essential for the mental and physical well-being of people living in cities. Improving the lighting and removing the railings alongside the path will help people to feel safe in the churchyard. There is no need to cut down the trees.
Yours sincerely,
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And just in case you want to read our full objection, here it is:
Dear Mr. Ipgrave,
Re: Planning application 20171911: St George’s Churchyard
We are writing to object to the above application. As Leicester Civic Society have already pointed out, the results of the public consultation about this development last year were inconclusive. We regret that the advice of the Economic Development, Transport and Tourism Scrutiny Commission, ‘that the proposal to remove trees at St George’s Churchyard should proceed with caution’, does not seem to have been followed. Our objections are outlined below.
Air pollution
St George’s churchyard is adjacent to the Air Quality Management Area (AQMA), where air pollution levels exceed legal limits. Leicester City Council’s Air Quality Action Plan outlines the importance of trees for reducing pollution:
‘In urban areas, trees, vegetation and green space can help absorb pollutants and improve air quality by absorbing pollutants, and preventing pollutant concentration.’ (p.35)[1]
Leicester Friends of the Earth are very concerned about the levels of air pollution in Leicester, given the links to stroke, heart disease, lung cancer, and both chronic and acute respiratory diseases, including asthma[2].
When this planning application was first discussed last autumn, we decided to measure the air pollution levels in the area. We put up four diffusion tubes to measure NO2 levels; two on the ring road and therefore within the AQMA (tubes 1 and 2), one in the middle of St George’s Churchyard (tube 4) and one approximately the same distance from the ring road as the churchyard but not in a green space (tube 3). The tubes were in place from 23/10/2016 - 11/11/2016. At this time of year, the trees were losing their leaves and therefore perhaps less able to absorb pollutants than they would be during the height of summer. The results from the diffusion tubes require calibration and adjusting alongside government figures, known as a bias adjustment. National Friends of the Earth consulted experts in monitoring and adjusted our results for accuracy using a bias correction factor for the type of diffusion tube we used. This involved multiplying our results by 0.92. The full laboratory report can be found in the separate file sent with this letter and the adjusted results are shown below.
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Location
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NO2
µg/m3
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Adjusted
NO2 µg/m3
|
|||||
|
70.16
|
64.55
|
|||||
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2. Junction Charles St/Ring Rd (LE1 1SH)
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60.89
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56.02
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3. Junction Colton St/Church St (LE1 1QH)
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46.67
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42.94
|
|||||
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4. Middle of St George's Churchyard (LE1 1RE)
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35.43
|
32.60
|
The legal limit value for NO2 is 40 µg/m3 in a calendar year. As our results clearly show, the level of air pollution along the ring road was considerably over the legal limit during our monitoring period. At Colton Street, which is approximately the same distance from the ring road as St George’s Churchyard, NO2 levels were lower but still illegal. However, in St George’s Churchyard, the levels of NO2 were below the legal limit. We therefore suggest that removing 21 trees will increase the level of air pollution, probably pushing it above the legal limit and leading to an extension of the AQMA. More importantly, removing the trees would threaten local residents' right to clean air.
We have been told that this development does not require an Environmental Impact Assessment. However, we believe that it falls into the category of ‘Urban development project’ in Schedule 2 of the Environmental Impact Assessment Regulations 2017[3]. The guidance from the Department for Communities and Local Government[4] states:
‘Projects listed in Schedule 2 which are located in, or partly in, a sensitive area also need to be screened, even if they are below the thresholds or do not meet the criteria.’
The selection criteria for screening state:
‘The characteristics of development must be considered with particular regard to:
…the risks to human health (for example, due to water contamination or air pollution)’
Therefore, we assert that this planning application (and all other planning applications that include the removal of trees either within or close to the AQMA), should have been subjected to an Environmental Impact Assessment and cannot be properly considered without that information.
The phrase ‘ignorance is bliss’ does not apply to air pollution; pollution that is not measured or acknowledged will still harm people. If the Council does not take pollution levels into consideration when deciding whether to approve or reject planning applications, they are neglecting their statutory responsibility for public health. Planning guidance[5] empowers local authorities to reject applications if there is reason for concern about air pollution and we believe that there is significant reason for concern in this case.
Biodiversity
Leicester City Council’s Core Strategy[6] acknowledges that, ‘Habitats that are beneficial for wildlife in the City include: small areas of woodland’ (p.91). We believe that St George’s Churchyard should be considered as a small wood. Core Strategy Policy 17 (p.93) states:
‘The Council will expect development to maintain, enhance, and/or strengthen connections for wildlife, by creation of new habitats, both within and beyond the identified biodiversity network.’
The Supplementary Planning Guidance on biodiversity[7] states:
‘4.10 Wherever possible, and as long as there is no conflict with public safety or amenity, mature trees and standing dead wood habitats should be retained. Rather than remove trees altogether, it is preferable to crown reduce or pollard trees in order to preserve at least some of the standing dead wood habitat.’ (p.20)
The Supplementary Planning Document on climate change[8] explains that green infrastructure mitigates the urban heat island effect, which will become more dangerous as the climate warms and heatwaves become more common. The importance of trees in combatting this problem is further emphasised in section 6.4, Planting:
‘Even modest increases in tree cover contribute to lowering the heat island effect. Mature trees and green spaces have far greater benefit than newly planted trees and so these should be preserved where possible.’ (p.6)
The Council’s own planning guidance does not allow mature trees to be cut down without a very good reason and no good reason has been given.
The Council say that the trees are damaging the church but no evidence is provided for this claim. The only reference to ‘damage’ is that fallen leaves have blocked the gutters. This is not a valid reason for removing trees - gutters can be cleaned and the value of trees far outweighs the minor inconvenience of removing fallen leaves. If the trees are causing structural damage, the Council should have provided full details and specified which trees are causing the problem.
It is proposed that the 21 mature trees will be ‘replaced’ by 8 saplings. Saplings can never replace mature trees, as noted above. The suggested replacement species, whilst attractive, with seasonal leaf changes and berries for wildlife value, will be smaller in stature even when they reach maturity and probably rather shorter lived. They will not provide the same amount of habitat for wildlife as the mature lime trees currently growing in the churchyard.
Anti-social behaviour
One of the main reasons given by the Council for the culling of so many trees in this area is that they encourage 'anti-social behaviour'. We believe that this aspect has been overstated and, in the longer term, this application may contribute to anti-social behaviour.
Anti-social behaviour occurs at many places around Leicester and to blame this on trees is nonsense. If security of the area needs improving then the lighting should be altered. A visit to this area at night shows that the lighting in St George's Churchyard is currently poorly located and not maintained. In other areas where security has been a concern, such as along certain streets, improved lighting has been the first thing considered. Removing the railings alongside the path will help to make the area less intimidating to pedestrians. If necessary, the Council could also consider judicious crown-lifting of the trees to make the path more open.
Removal of trees and reduction of natural areas has actually been shown to increase the likelihood of anti-social behaviour. For example, Kuo and Sullivan, (2001a, 2001b) showed that urban areas with higher vegetation cover have lower rates of crime.[9] The recognised value of ‘natural environments’ to human health and wellbeing has been a topic of extensive systematic study for 30 to 40 years, and amongst these the affective impact of trees features prominently[10]. Removing trees to reduce anti-social behaviour may actually be counter-productive.
Process
There seem to be some errors of process with this planning application, which we find concerning. The Land Registry information for the church and churchyard shows that there are protective covenants on this property, which the Council do not seem to have addressed. For example, it is stated that ‘the removal or disturbance of any tombstone monument or memorial on the said property’ is forbidden without the consent of the commissioners. Have the Council consulted the church commissioners about moving the gravestones? There is no indication of whether this has been done.
We also note that, Munro Whitten, the landscape architecture consultants, are based at the LCB Depot. The LCB Depot is shown on the plans as having a new direct connection into the churchyard, which itself requires the removal of some trees. It is a conflict of interest for this architect to have worked on a proposal from which they stand to benefit and the Council should have been aware of this and chosen a different architect. Finally, we note that a response in support of this application has been submitted by the businesses nearby, who are presumably intending to use the new space to expand their seating area. It is inappropriate for those who stand to materially benefit to respond to the planning application and we ask that this submission be disregarded.
The importance of trees for clean air, wildlife habitat, cooling urban areas and improving physical and mental well-being has been recognised recently in the Charter for Trees, Woods and People[11], which has been created by more than 70 organisations and signed by more than 90,000 people. Leicester City Council have recognised this in their policies and planning guidance too. We do not understand why these policies have been ignored recently and why the Council are trying to remove healthy, mature trees. We call on Leicester City Council to return to their previous understanding of the importance of trees in an urban area and refuse consent for this application.
Yours sincerely,
Hannah Wakley
Joint Co-ordinator of Leicester Friends of the Earth
[1] Leicester City Council’s Air Quality Action Plan. Retrieved from: http://www.leicester.gov.uk/media/180653/air-quality-action-plan.pdf
[2] World Health Organisation Factsheet, ‘Ambient (outdoor) air quality and health’. Retrieved from: http://www.who.int/mediacentre/factsheets/fs313/en/
[3] The Town and Country Planning (Environmental Impact Assessment) Regulations 2017. Retrieved from: http://www.legislation.gov.uk/uksi/2017/571/contents/made
[4] Department for Communities and Local Government guidance - Environmental Impact Assessment. Retrieved from: https://www.gov.uk/guidance/environmental-impact-assessment
[5] Department for Communities and Local Government guidance - Air Quality. Retrieved from: https://www.gov.uk/guidance/air-quality--3
[6] Leicester City Council. Core Strategy. Retrieved from: http://www.leicester.gov.uk/media/179023/core-strategy-adopted-july-2014.pdf
[7] Leicester City Council. Supplementary Planning Guidance - Biodiversity in Leicester. Adopted 13th October 2003. Retrieved from: http://www.leicester.gov.uk/media/179106/biodiversity-in-leicester-spg-october-2003.pdf
[8] Leicester City Council. Supplementary Planning Document - Climate change. Adopted January 2011. Retrieved from: http://www.leicester.gov.uk/media/179107/climate-change-spd-january-2011.pdf
[9] Kuo, F.E. & Sullivan, W.C., (2001a), Environment and Crime in the Inner City. Does Vegetation Reduce Crime? Environment and Behavior, 33(3), 343 - 367.
Kuo, F.E. & Sullivan, W.C., (2001b), Aggression and Violence in the Inner City - Effects of Environment via Mental Fatigue, Environment and Behavior, 33(4), 543 - 571.
[10] Wikiversity. Psychology of natural scenes. Retrieved from: https://en.wikiversity.org/wiki/Psychology_of_natural_scenes
[11] Woodland Trust. Charter for Trees, Woods and People. Retrieved from https://treecharter.uk
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