Civic Society Comments 2007

BRISTOL CIVIC SOCIETY
RESPONSE TO SHAPING BRISTOL OVER THE NEXT 20 YEARS
BRISTOL DEVELOPMENT FRAMEWORK - CORE STRATEGY
ISSUES AND OPTIONS PAPER - JULY 2007
SUMMARY OF THE CONTENTS OF THE RESPONSE

1. We support the City's priority to develop previously developed land before any green belt land is lost and to require any proposal to develop on green field land to demonstrate that there are no alternatives on previously developed land.
2. We believe that the City has yet to appreciate the strength of development pressure that it can harness to enable it a bold positions to secure its preferences.
3. The Options fail to address the urgent need to address the current state of the City's traffic congestion. Without radical policies to control traffic, congestion and air quality will worsen and improvements to public transport will be unachievable.
4. We prefer Spatial Option 1. Suburban regeneration will spread growth across the City to make pleasant areas in which to live, which are accessible to public transport and will minimise traffic growth. Within this preference we recognise South Bristol's need for regeneration.
5. We prefer Housing Density Option 3 - there is no "one size fits all" solution. In the Centre the City should aim for very high density of mixed residential units. We believe that it is short sighted for the City to permit the continued development of tiny residential units.
6. We prefer Housing Type Option 2 to promote a greater variety of homes.
7. To achieve its affordable housing target the City has the opportunity to take bold positions with developers to secure its preferences. The dynamism of the local economy gives the City the opportunity to negotiate from strength.
8. We regret the apparent absence of joint planning strategies across the sub-regional housing market.
9. Section 2 - Objectives for Bristol - we question whether this section of the questionnaire can achieve its purpose and whether it is an appropriate method by which to involve the public in a consultation about difficult policy proposals.

1 Introduction
The Bristol Civic Society (the Society) welcomes this Issues and Options paper (the Paper). The Society responded to the draft Regional Spatial Strategy and was invited to attend its Examination in Public. We responded to the Paper "Shaping Bristol", in November 2006, to the Waste Consultation of February 2007. We responded to the "The Council's Approach To Planning Enforcement" in July 2007. Together with the Bristol Local Neighbourhood Planning Network we have actively helped the City to draft its revised Statement of Community Involvement.
What we support
2 We welcome Bristol City Council's (the City) statement of community involvement at section 1.3 which introduces the Paper We share the City's five long-term aims described in section 2.1. The research listed in the Spatial Atlas, supplemented by the further studies in progress appears to us to support the City's confidence that its Core Strategy has a sound evidence base.
3 We share the City's aim to meet the growth targets indicated by the 2004 Sub-national Population Projections for Bristol whilst allowing for flexibility of demand should those projections change over the next 20 years. We share the City's priority, advanced in section 2.4, to develop previously developed land and regenerate South Bristol before any green belt land is lost. We support the City's view that any proposals for development on green field land will be expected to demonstrate that no reasonable development opportunities remain on previously developed land.
Reservations
4 We are at a disadvantage to the Strategic and Citywide Policy Team (the Team) who have drafted the Options Paper because we can never achieve their depth of knowledge of the City's evidence base. We have not shared the Team's widespread discussions about the advantages and drawbacks of proposed options: the spatial atlas provides much information, but remains insufficient for stakeholders to evaluate the Options. In particular, current property market information is important, and we lack the insight that knowledge of development enquiries give. We expect the stakeholder meetings set up for September to help fill in the gaps in our knowledge, and we reserve the right to make further comments in the light of this.
5 We recognise the problems in drafting the Paper but we are disappointed with some aspects of it:
The 18 issues and 7 objectives are too general. They tend to repeat the high-level analysis of the Draft South West Regional Spatial Strategy (the RSS), rather than make them local-specific and selective, as they should be at this stage of the Core Strategy process. We expand on this point below.
Whilst the options presented are rightly local-specific and selective, there is insufficient commentary to enable evaluation - particularly the spatial options. For example:
" The impacts on infrastructure, employment, transport, traffic, centres are not explored in any detail.
" There is no assessment of whether the spatial options are realistically achievable
" It is not easy to compare and contrast the three spatial options. The maps for each spatial option are identical in most respects, and the key difference - location of new development in quantitative terms - is not presented in a way that is easy to compare and contrast.
Whilst the next steps in the Core Strategy process are explained in terms of a series of documents, with the next one being 'Preferred Options', there is no explanation of when and how the more detailed analysis of options will be presented to stakeholders. Ultimately, one would expect to see a map of the whole of Bristol, showing a coherent pattern of planned development, centres and infrastructure across the city: when will that appear?
The paper is confined to Bristol, and ignores the RSS's proposed urban extensions to Bristol in the three neighbouring local authority areas. It is disappointing that a Core Strategy cannot be written that encompasses the whole of the Bristol conurbation. Whilst we accept the reality of the situation, we would like to hear of some joint approach across the four local planning authorities (LPAs). We hope that the above aspects will be addressed in the stakeholder meetings in September.

6 Section 2 - Objectives for Bristol
We question whether this section of the questionnaire can achieve its purpose.
The objectives are inevitably of a general nature. We do not see any logical connection between most of the objectives and the issues that they are said to address. For example, without further explanation, why should Objective 1, planned sustainable development and growth, address related issue 10, to protect and enhance Bristol's historic environment? Why should sustainable development and growth relate to issue 13, to reduce pollution? One could say that this objective fails because growth cannot reduce the current levels of pollution in the City Centre and Air Quality Management Areas.
There are many other problems with this questionnaire both textural and of substance. What does "providing hooks to ensure a high achieving economy mean?" How can the City "ensure sustainable development in sustainable locations accessed by public transport" when the provision of public transport lies outside its powers?
It would be too easy to tick all the boxes to approve the City's vision. We cannot see anyone failing to agree with the seven general objectives. However, to reduce what will generally be a qualitative response to a binary answer to be scanned to produce a quantitative analysis cannot in our view produce any useful information. We believe that the answer of most respondents to the questions would be qualified. The best we can do is to list some of the issues addressed to which the proposed actions do not respond.

6.1 Objective 1 - Ensuring a sustainable future
No action is proposed to address the problems that the baseline conditions of the various reports listed in the Spatial Atlas. For example, how do the actions in response, propose to:
(i) Reduce the current levels of air pollution?
(ii) Improve poor quality housing stock? Probably about 85% of the housing stock in 2026 will built, pre-2006.
(iii) Protect and enhance Bristol's historic environment?
6.2 Objective 3 - Ambitious and Sustainable Growth
Why should Bristol seek to "maintain the economic growth of Bristol above the regional and nation level of economic growth?" Either this is consistent with RSS, in which case it is less straightforward to argue against it; or it's not consistent with the RSS and we should say so. The City's own data shows that it already has the highest level of economic growth in the south-west region. The City's traffic causes it to be one of the worst congested British Cities. The housing market is out of balance, excess demand has inflated house prices.
To aim for gross economic growth over-simplifies the issue. Gross economic growth will merely accelerate traffic congestion and house price inflation and will adversely affect the quality of life of Bristol residents.
Gross economic growth will not address the imbalance of economic achievement and give improved employment opportunities in the poorer super output areas of the City. Gross economic growth may principally benefit people who choose to travel to work in Bristol from neighbouring LPAs to avoid living in a traffic congested City that has poor air quality.
Objective 3 fails to make any reference to the Regional Spatial Strategy's sustainability policies. The unreflective pursuit of gross economic growth will destroy those qualities that make the City a pleasant place in which to live, to work and to visit.
6.3 Objective 5 - Better Health and Wellbeing
This objective would be more persuasive if the Paper proposed specific policies to replace lost school playing fields and to improve the inadequate maintenance and management of the City's existing open spaces.
"Ensure by a clearly defined and widely shared sense of the contribution of different individuals and different communities a common vision for the city." This political slogan does not add to a reasoned debate. It is beyond the City's power to deliver.
6.4 Objective 6 - High Quality Built and Natural Environment
Section 1.1 of the Paper describes the strength of development pressure in Bristol. Section 2.2 depicts the City as "the driver for the economy of the South West." We believe that the City has yet to appreciate the strength of the development pressure that it can harness to enable it a bold positions to secure its preferences. The City has the opportunity to harness this economic strength to take a bold position to secure its preferences.
6.5 To achieve issues numbers 10 - 18 the Action in Response should include statements to show how the City proposes to:
(i) Enhance Bristol's historic environment.
(ii) Improve the quality of urban design.
(iii) Improve the planning enforcement function.
(iv) Improve the management of parks and open spaces.
(v) Introduce urban design into highways standards and management.
The City should use its strong negotiating position to demand from developers improved urban design and to reject designs that fail to achieve the better design standards set by the Government for LPAs to achieve. This demand for improved design standards must also apply to its own Highways Department.
6.6 Objective 7 - Improved Accessibility and Connectivity
The Paper fails to address the urgent need to address the current state of the City's traffic congestion. In our view this is a major failure. Whilst we recognise the initial political unpopularity of attacking the City's dominant car culture, the evidence from other cities that have introduced traffic reduction schemes shows that these policies quickly become popular as soon as their effects become noticeable. The Paper fails to propose policies to introduce
(i) controlled parking zones in the central wards, and
(ii) Traffic restriction schemes in the central area.
Without radical policies to control traffic, both congestion and air quality will continue to worsen, and far-reaching improvements to public transport will be impossible to achieve. Will the City Centre Schools be sustainable without adequate public transport? The City's Quality of Life Indicators and Air Quality Statistics support the Society's stress for the need for immediate and active traffic management policies. Suitable policies can be seen in other cities in Britain and on the Continent. We need the benefit of these policies, now. No one will acknowledge the City's Green Aspirations until it develops an alternative transport policy to car dominance.
6.7 The Core policy to "Support maintenance, management and the improvement of the existing road network," means in our view, "Build more roads." For example, although we do not support it, we understand the argument that the proposed south Bristol Ring Road is integral to the regeneration of south Bristol to give commercial transport better access. However, where is a policy to prevent the road generating more private car use which will have access to the City centre?
The City's strong economy enables it to adopt radical traffic restriction policies in the centre of the City confident in the knowledge that the local economy will rapidly adjust to profit from the opportunities that less congestion will bring.
6.8 There is little or no indication that any of the three core strategy options concentrate proposed development on existing rail or proposed rapid transit routes. The spatial planning has not taken into account the contribution which the rail network could make to accessibility and connectivity. This is evident from the three option maps. In this respect, opportunities for such sustainable development around rail stations such as Clifton Down, Lawrence hill and Parson Street seem to have been overlooked. Such sites should be developed with priority and Section 106 funds allocated to support the development and operation of associated rail services in order to minimise car use.
6.9 Park and drive schemes work. Two new platforms are under construction at Bristol Parkway. Park and ride schemes should have direct access to existing stations. There are closed stations that could re-open. These are examples:
" Ashton - access to the south west railway or an extension of the old docks railway.
" Avonmouth - could have access to the Clifton Down Suburban line.
" Portishead - access to an upgraded goods only line.
" Keysham and Hicks gate - access to the London main line.
The Department of Transport's South West Regional Plans for the Railway (May 2007) omits any reference to these obvious, achievable and long discussesed schemes. The Bristol Core Strategy's horizon is 2006. Why does it not include a vision for the development rapid mass passenger traffic for the whole of this period? The Government has advised the City that its population, and traffic flows will increase.
Where are the proposed improved transport interchanges to be?
7 Section 3 - Developing the Spatial Options for Bristol
We understand the City's desire for a quantitative assessment by the people of Bristol of their preferred spatial option to be included in the Core Strategy. We question whether this section of the questionnaire can achieve its purpose because:
7.1 There is insufficient information on which to form an opinion. Please see our comments at 4 and 5 above.
7.2 The City has limited financial resources. The best use that the City can make of public funds is to use them to attract and complement the investment of private money. To a significant degree the City is in the hands of those with money to invest in business, commercial development and house building and transport. The Society is not aware of the development enquiries that the City has received, which will affect the feasibility and the succession of various regeneration proposals. Please read our choices subject to this reservation.
7.3 Many of the people who will be affected by redevelopment will not respond to this Paper. Whilst most will accept the principle to direct future development and growth to Balanced and Sustainable Community Project Areas across the City, the implications of this approach will be locally important. The projects will increase local population density, build on green space and demolish property. People generally resist change. There are strong folk memories of population displacement that accompanied slum clearance in a previous planning age. People will react against any development proposal unless they can see the improvement that redevelopment will bring. Comprehensive community engagement must be established from the outset, as a fundamental method to ensure that proposals embody local needs. These methods must include a clear and trustworthy visual representation of the area following redevelopment.
7.4 The Harbourside experience has left a sad legacy of public mistrust. The Masterplan was settled after a long-running public debate about the quality of development that the public wished to see in one of the most sought after and prestigious development sites in the country. There was massive public involvement. What the public gained through its involvement with the Masterplan it lost through the aggregate of cumulative revisions to the development consents about which it was not consulted. On the 7th August2007, the Times featured one of the Harbourside buildings in a "Ten worst buildings of 2007 competition" - a view widely shared by many Bristol residents. It is difficult to overstate the depth of public disappointment at the outcome. There should be a general policy that once a Masterplan has been adopted after public involvement, no significant departure from a Masterplan should be allowed.
7.5 We believe that the Paper lacks vision about how the City can adapt to profit from new technology. Bristol residents have always embraced work style change. There is the opportunity to develop Internet Hubs in the Balanced and Sustainable Community Project Areas. This would devolve office working from the centre. The suburban centres would offer more economic opportunities for their residents and reduce the need to travel. It will probably be necessary to reduce the development options in the City Centre to divert employment to the suburban regeneration projects.

8.1 Spatial Option 1 - Focus on centres and balanced and sustainable community projects across the city.
In principle, we strongly support the Balanced and Sustainable Communities approach. If anything embodies the City's spatial vision, it is this approach.
We prefer this option. We agree with the Paper's description of the strengths and benefits and challenges of this option. We believe that this option will best serve the City because it will spread growth across the City. At the same time it will make use of existing centres to make pleasant areas in which to live. It will focus growth in areas that are most accessible by public transport and reduce the need for car journeys.
The northern arc and central south areas, which require regeneration, have the capacity to absorb additional residential growth. Some of these areas have poor public transport links and infrastructure. Additional population will improve the viability of transport and other infrastructure. However, this infrastructure must be planned and integrated into the development. Sites around railway stations should be developed first.
We add these points:
(i) We note that the Paper does not include any specific references to the development of the river. The Avon identifies Bristol in the public mind and makes it special. The whole central area should have a masterplan. The river should be at the centre of the Masterplan to create a City Centre worthy of a regional capital.
(ii) We are confident that private investment can achieve most of the City's desired development of the City Centre. At paragraph 6.4 we argue for proper traffic management policies. This need applies particularly to the City Centre. Pedestrian priority has been adopted by many major Continental Cities.
(iii) We suggest that the City revisits its Tall Buildings Supplementary Planning Document following the publication of Commission for Architecture and the Built Environment's (CABE) "Advice on Tall Buildings" - July 2007. It is necessary to decide where the city's landscape can accept a cluster of tall buildings. Unrelated tall buildings scattered through the landscape are unpopular.
(iv) At 9.8 we describe the disadvantages that the concentration of tiny one and two bedroom accommodation in the City Centre will produce.

8.2 Spatial Option 2 - Enabling growth and expansion of the City Centre.
This is the option that we least prefer. It appears to increase the imbalance between the City centre and the outer suburbs, which needs to be resolved before the City centre expands. We agree with the Paper's description of the strengths and benefits and challenges of this option and add these points:
(i) The City Centre will continue to provide employment land and homes. If the City's economy remains buoyant for the next 20 years, developers will seek and find opportunities in the St. Philips area without the need for regeneration project support. This would permit the City to commit regeneration resources to other areas.
(ii) A more gradual approach to the regeneration of St. Philips will permit the redevelopment or redeployment of existing businesses over an extended period. The gradual redevelopment of the area may very well mean that ordinary business forces, rather than the City's policies will bring about a gradual change in the pattern of employment. A gradual approach will put least demand on the provision of new infrastructure.
(iii) We are not concerned about the loss of office accommodation from the City Centre to St. Philips. Does it matter that more office accommodation is lost in the City Centre to residential redevelopment?
(iv) If St. Philips is not a re-generation centre it is desirable that the area is subject to a masterplan, probably by stages. We note that redevelopment may require costly new infrastructure. St. Philip's Marsh has very poor public transport access, which must be resolved before major development can take place. The Paper only appears to refer to the need for roads and bridges.
(v) This Option estimates that St. Philips could provide 3,000 new homes from 2012. Is there any reason why this area should not continue to be able to provide housing development land if this Option is not preferred?

8.3 Spatial Option 3 - Focusing on South Bristol
We agree with the Paper's description of the strengths and benefits and challenges of this option subject to these reservations:
(i) We recognise south Bristol's need for regeneration that the Paper describes. We question whether the needs of the central south area are greater than those of the suburbs of the northern arc or the east side. All appear to show a need for increased economic development and regeneration.
(ii) This option invests most of the City's capital, both money and planning effort, in one area. All investment should spread risk. If South Bristol is the principal regeneration project over the next 20 years and for reasons that are unforeseeable and lie beyond the City's control, the regeneration project falls short of the Bristol Partnership's aims, residents in the other regeneration areas will regret the lost opportunities. If regeneration is invested in several areas then, if some regeneration projects are less successful, others will succeed.
(iii) We suggest that a balance is struck between the northern arc, the eastern suburbs and the south central area with the south central area as the first among equals. We accept that our comments may fail to recognise economic facts known to the Team and not to us. There may be specific arrears of land where regeneration plans have progressed. In other areas it could prove too difficult to assemble packages of land that are large enough to attract developers. The City Council may already have received indications of inward investment into a regenerated south Bristol. These factors could outweigh our suggestion that Option 3 appears to put south Bristol regeneration before the demands of other areas in need of regeneration.
(iv) If south Bristol's housing capacity can be exploited then, towards the end of the first half of the period of the Core Strategy, the City can reassess the housing demand in the knowledge that St. Philips retains a capacity to provide housing land.

9 Housing Policy Options
9.1 1 Housing Density
We prefer Option 3: variable density figure relative to accessibility.
2 Housing Type
We prefer Option 2 to promote a greater variety of homes across the City. There is no "one size fits all" solution because there is no finite solution. We draw attention to "Towards good practice in sustainable urban land use" - published in 2002 by the Bristol LA21 Land Use Group in Association with the Architecture Centre, Bristol and supported by Bristol City Council (Good Practice). It is convenient to consider both of these policy options together.
9.2 In the suburbs, at the centres of Sustainable Community Project Areas the City should aim for as high a density as is possible to exploit urban capacity. High Density involves compact rather than high rise living, without overcrowding. It can create a hierarchy of heights with hard and green enclosed spaces for the community. Regeneration can enhance heritage buildings and promote any local distinction to make the urban village more attractive. Mixed use development will bring about a more sustainable community with a higher quality of life for its residents.
Compact living will promote these advantages:
" The destinations of the residents' most frequent journeys will be within walking distance. This reduces the need for private car journeys.
" Compact living creates the need for well used routes that have pedestrian and cycle priority, which the residents enjoy using. Cycle ways and pedestrian cut-throughs use less land than streets designed to highway standards and are more attractive public urban spaces.
" Compact living increases the potential customer base and makes local services and businesses more viable. An increase in activity promotes more employment.
" A critical population density is necessary to make public transport economically efficient which can lead to improved public transport links to citywide facilities.
" Compact living improves the natural surveillance of the streets.
" Compact, high density regeneration reduces the pressure to build on ecologically valuable green space and produces the resources to improve and maintain green space necessary for a diversity of outdoor activities.
" Compact development reduces the use of natural resources and makes recycling and waste collection simpler.
"Good Practice" quotes Orlebar Gardens as an example of how to regenerate a building that has come to the end of its useful life and is detrimental to its occupants and neighbours. The City transformed a rundown building to become high quality, high density secure dwellings with a communal green space and play area.
9.3 In the City Centre the City should aim for very high density of residential units. However, we believe that it is short sighted for the City to permit the continued development of tiny residential units. Planning Policy Statement 3 (PPS) published as recently as November 2006 gives advice about the advantages that mixed housing achieves. The Paper fails to explain why the City permits developers to continue to build an excess of tiny one and two bedroom flats contrary to the advice of PPS3. The current approach is unbalanced. It must change because it is contrary to PPS3 standards fails to meet the City's future needs.
9.4 The population that lives in tiny one and two bedroom flats will be transient and will not create a sustainable community. The City ward profiles shows that Cabot ward has a disproportionately high number of young adult residents and a low number of children. We contrast the developing City Centre property market with mature, established City Centre housing markets such as Edinburgh and Bordeaux where there is a greater diversity of apartment size. This is another example of a situation in which the City can harness its economic success to secure its housing preference.
9.5 Generally, the smaller the size of the individual residential units the greater the profit for the land owner. The price demanded for development land is contingent upon the development permission that the owner believes that can be achieved. If the City adopts a socially sustainable policy that requires a mixture of apartment type and size, the development housing market will quickly adjust its expectations to the City's policies.
9.6 Many of the blocks of tiny flats in the City Centre have street level "car park grills" instead of active street frontages. The design of many of these blocks fails to achieve PPS3 standards. There is a wealth of guidance about design contained in, for example the CABE's publications.
9.7 One of the major problems that the City will face will be to persuade the residents of an area that is promoted for housing led regeneration to accept change. We refer to our comments at paragraph 7.3 above. Design that fails to reach the quality demanded by PPS3 will make this problem worse. Although CABE's Housing audit: Assessing the design quality of new housing in the East Midlands, West Midlands and the South West February 2007 paid complementary remarks about the City's redevelopment of Horfield, most of the audit is critical of developers' design standards. The Paper does not say how the City will organise itself to achieve the improvement in design standards at which it aims. Will there be an attempt to raise housing design on a sub-regional basis? The Paper does not say.
9.8 We are concerned that there is no reference in the Paper to housing development to be achieved through collaboration at a sub-regional level. Greater Bristol overlaps local authority boundaries, for example Kingswood. Bristol is an English Core City. The Government promotes housing development strategies at the City Region level. Whether the question relates to issues of density, new housing location or forming partnerships with developers, national planning policy stresses the importance of working across local authority boundaries and aligning housing strategies in sub-regional areas. The RSS is drafted on the basis of sub-regional housing markets.

10 3 Affordable Housing
We prefer the higher thresholds of Option 1 for Central Bristol and Option 4 for Inner and Outer areas of Bristol. We support Option 5 because mono-tenure housing in neither in the interest of its residents nor of the City. Mixed tenure gives residents a flexible approach to house ownership and renting. Mixed tenure helps to improve areas which have pockets of poverty where low income families have limited employment opportunities and they lack the means to travel to find work.
10.1 We read with interest the "Three Dragons" advice about the number of social housing units land owners and developers will tolerate before they seek planning permission to develop land for a non-housing, alternative use. We understand that other planning authorities in English Core Cities achieve a higher proportion of affordable housing units. We suggest that the City sets its policy in line with the levels that can be achieved elsewhere. We understand that some local authorities set the threshold for a contribution to affordable housing at 10, in line with Government Guidance. This is another example of a situation in which the City can harness its economic success to secure its housing preference.
10.2 The City's current policies delivered 16% affordable housing in 2004/05 - Intelligence West - Housing Monitoring Report 2006. The Government's target is 30%. Housing objectives and policy targets must be transparent and publicly available. A developer's economic argument that it cannot afford to achieve the target proportion set for affordable housing should be made public.
10.3 What are the targets set by the other unitary local authorities in the sub-region? The Paper does not say. Levels of affordable housing are a policy that must be settled on a sub-regional basis if the City is to manage a market that is dominated by the economic power of national house developers. We believe that a uniform affordable housing policy will lead both land owners and developers adjust to the changed climate of development expectation. It is not profitable to add any further comments about the provision of affordable housing because of the advice on this subject available from the Housing Corporation.