Civic Society Comments

 

Introduction

This response to the Preferred Options paper comes from the Bristol Neighbourhood Planning Network (BNPN) and the Bristol Civic Society (BCS).  Both organisations have previously submitted responses to earlier stages of Bristol’s Core Strategy consultation.  BNPN is a network of community organisations across Bristol.  It is specifically recognised in the draft Statement of Community Involvement (SCI) as one of the organisations that may be used to support a wider range of community involvement.

We have, as requested, structured our response in line with the questions asked by the consultation, but we have wider reservations about the proposals that do not fit such a structure.  To express these reservations, we also attach:

	An analysis of the City’s Preferred Strategy - why we believe the process to be flawed, and
	An outline of our own alternative preferred Spatial Strategy Option.

We are disappointed with the paper.  We expect the Core Strategy in its current form to fail the tests of soundness.  We see this as a problem both of the content and presentation.  We believe that the City’s thinking is more substantial than can be read from the Paper but we can make a judgement only on what is presented to us. 

These are our concerns:

1        A list of 23 policies is not a strategy.  A spatial strategy should address the conflicts between objectives within specific areas, allowing for the social and environmental characteristics of the area.  Of the 23 policies in the paper, the first 6 are spatial but are too vague: the other 17 policies (the Development Principles) do little more than rewrite the objectives in different words.

2        The proposals are too vague and aspirational.  There is insufficient description about the centres of sustainable development and their different urban characteristics.  The Paper should articulate a strategy that minimises private car journeys and that links transport, employment, housing and access to the City’s physical, social and recreational infrastructure.  Surely the City’s work on Balanced and Sustainable Communities, the Comprehensive Regeneration Framework and the work done for south Bristol enable it to say more?  The proposals do not form a strategy that gives clear direction for future area action plans.  Too much is being left to future Development Plan Documents.

3        The process is flawed

·         The choice of option is not sufficiently justified,

·         The document does not follow good practice guidance,

·         The document is likely to fail the tests of soundness. 

Proposed Spatial Vision

Q 1    Does the proposed Spatial Vision adequately reflect the Key Issues facing Bristol?

1.1              We answer, it does, in part.

1.2              The spatial vision tries to integrate too many things.  It includes elements of the Sustainable Community Strategy (SCS), by stringing them together in the same sentence.  It should be selective to create a vision.

1.3              The Spatial Atlas does not refer to any Urban Characterisation Study.  The legibility of the Core Strategy, submission version would benefit from a brief spatial portrait of different areas of the City.  Bristol is formed by a number of distinct urban and suburban neighbourhoods.  An introductory chapter to the Core Strategy chapter would illustrate the relevant matters.  It would identify the social, economic and environmental / physical issues that face the City.  The spatial vision for the City and the strategies to deliver that strategy would follow naturally.

1.4              If the Core Strategy, submission version follows the same form as the Paper, it will not convey a picture of the City at the start of the plan’s period.  We suggest that a spatial portrait of the City should contain a description of

·                     the physical appearance of the City and its built environment;

·                     its demography and its social and economic gradients;

·                     its housing stock and the problems that are associated with it;

·                     the City’s economy and the related problems such as areas of social deprivation and the existing regeneration schemes;

·                     the City’s internal transport system and its external transport links. 

This information can be extracted from the preserved Bristol Local Development Plan and updated from the Ward Profiles.  The Profiles refine each Ward into its super output areas.  In contrast, Brighton’s Preferred Options paper (see http://tinyurl.com/2fdu8p), devotes 74 pages specifically to exploring the links with its SCS’s aims.

1.5              The Core Strategy guidance says that there should be links with the Sustainable Community Strategy (SCS).  Although the Paper quotes the aims of the SCS it does not clearly show the links to of the SCS vision. 

1.6              The description of the City’s Spatial Vision is mainly in the form of aspirational policies.  The only reference to a proposed concrete policy is to regenerate South Bristol and part of St. Philips.  The reference to the “Northern Arc and City / East Areas” (the other regeneration areas) is very general.  We infer that the City’s preferred option in respect of any area other than south Bristol and St. Philips is business as usual.  The Core Strategy’s purpose is to make the difficult policy decisions, not to put them off to be decided in later Development Plan Documents (DPD).  What did the City learn from Community Involvement at the Issues and Options stage?  The Paper does not say. 

Proposed Spatial Objectives 

Q 2    Will the proposed Strategic Objectives help to deliver the proposed Spatial Vision for Bristol?

2.1              We answer, they do, in part.

2.2              The Paper at Paragraph 4.1 incorporates and modifies the objectives included in the July 2007 Issues and Options document.  It is difficult to understand how each strategic objective will appear in the Core Strategy, submission version.  We would have preferred to comment on fully developed strategic objectives and not have to make any further comments to the final iteration of the Core Strategy prior to its submission for Government approval.

2.3              How will conflicts between strategic objectives be resolved?  What weighting will different objectives be given?  Will meeting the numerical housing target over-ride other objectives that are not so quantifiable.  

Q 3    Are there other Strategic Objectives which we should include?

3.1              The Spatial Vision and Strategic Objectives are aspirations that all will approve.  However, they should be specific to Bristol so that the Spatial Vision leads naturally to the strategies and actions to implement that vision. 

The Preferred Spatial Strategy Option 

Q 4    We consider that the Preferred Spatial Option will deliver the proposed Spatial Vision and meet the proposed Strategic Objectives.

4.1              We answer that we strongly disagree. 

4.2              This section is insufficiently developed.  The Core Strategy will be superficially consistent and coherent, but not detailed or integrated enough to be effective.  We note that the Core Strategy allocates 40% of new housing to south Bristol.  It proposes some specific locations and a potential new district centre but does not explore the spatial implications.

4.3              The Paper refers to the Research and Evidence Base.  It would strengthen the coherence of the Core Strategy, submission version if it listed the evidence studies that have significantly influenced the City’s Preferred Spatial Options and quoted each study’s principal conclusion(s).  This would link the evidence to the reasons to adopt each preferred option, which is what the public requires to understand the Paper.  We note the large areas that the map on page 16 delineates.  It would help to have the boundaries identified.

4.4              The Paper does not explore the argument that links the Strategic Objectives in Part 4 to specific spatial options listed at paragraph 5.6.  There is no discussion of any alternative approaches to accommodate the City’s predicted growth over the next 20 years.  The preferred options papers prepared by other Local Planning Authorities that we have read consider the strengths and weaknesses of the preferred options and the alternatives. 

4.5              For example, Brighton’s document uses a range of tests against which to decide and explain the merits of each of the development options:

·                     An accessibility-led approach to permit of housing and employment development through higher density in areas selected upon their accessibility to sustainable travel.

·                     A regeneration-led approach - based upon regeneration needs.

·                     An urban capacity-led approach – based on a Super Output Area analysis of each area’s capacity to absorb housing and employment development.

4.6              Because this section gives so much space to the description of new housing provision to meet the RSS RHA targets, the Paper lays itself open to the criticism that its approach is to develop the largest strategic sites that give least site assembly problems to provide the maximum number of houses to meet the SWRSS housing target. 

4.7              Economic, social and community regeneration is not the same as a programme of new house building, which will not automatically lead to improved sustainable employment in south Bristol.  Equally, because of the existing level of unemployment, improved employment opportunities can be filled from the resident population.  The economic, social and community regeneration of south Bristol is a separate issue to the delivery new housing.  These issues should be de-coupled in the Core Strategy. 

4.8              We endorse and adopt the extended answer to this question made in the Hartcliffe & Withywood Community Partnership’s response. 

Q 5    Should the Preferred Spatial Strategy Option include additional features?

5.1              We answer, yes.

5.2              The Paper should say what the City learnt from Community Involvement at the Issues and Options stage.

5.3              The Paper should state that the City will promote development on brown field sites within the built-up City and will permit urban extensions only later in the plan period when the Housing and Employment Land Studies show that growth cannot be accommodated without green field development.  The option is to be preferred because:

(i)                 It will promote suburban regeneration.

(ii)                It will lead to more sustainable communities and reduce the need for car journeys. 

(iii)               It will prevent urban sprawl and preserve the countryside that surrounds Bristol to fulfil its Green City ambition.

5.4              The Paper must be more specific in its designation of the areas where it proposes to direct significant mixed-use development.  The descriptions, “northern arc”, “inner city / east side” and “south Bristol” are too vague.  “South Bristol” means anywhere south of the Avon – 40% of the City.

5.5              It would improve the legibility of the Core Strategy, submission version if the Paper set out the City’s reasons for choosing its Preferred Option. 

5.6              Were there any further options considered by the City or proposed through Community Consultation?  What were the reasons for their rejection?

5.7              What were Sustainability Appraisal’s findings?  Were there any adverse findings?  Did it recommend any mitigation measures?  The Paper does not say.  It would strengthen the coherence of the Core Strategy, submission version if it summarised the Sustainability Appraisal’s conclusions.

5.8              To improve the legibility of the Core Strategy, submission version the Paper should list the Local Development Framework (LDF) documents by which the City will implement its preferred option(s) and name the City’s delivery partners. 

Q 6    Do you have an alternative strategy?

6.1            Northern & Southern Suburbs

Southmead, Lawrence Weston, Henbury, Lockleaze, Hartcliffe, Withywood, Knowle West and Filwood are suburban areas of social deprivation and high car use in need of urban regeneration.  The urban renewal strategic objective for local and area action plans will:

·         Reflect the character of the local area and the results of community involvement.

·         Reduce social deprivation and exclusion.

·         Increase overall housing densities and mixed use by selected site development.

·         Reduce the need for journeys by car by redeveloping local services with easy access by foot, bicycle and efficient public transport.

Implementation will use the integrated approach of the Balanced and Sustainable Communities programme.

6.2            Inner City

Lawrence Hill, Ashley, and Easton, including St Paul’s, Redcliffe, Barton Hill and St Philips are inner city areas of social deprivation. The urban regeneration strategic objective for local and area action plans will:

·         Reflect the character of the local area and the results of community involvement.

·         Reduce social deprivation and exclusion.

·         Rebuild the local economy.

·         Re-design and re-configure the local townscape to recreate local centres and give strong links to the city centre.

Implementation will use already established neighbourhood partnership programmes as part of the integrated approach of the Balanced and Sustainable Communities Programme. 

6.3     We endorse and adopt the extended answer to this question made in the Hartcliffe & Withywood Community Partnership’s response.

Proposed main elements of Core Policies 

Q 7    Will the proposed Core Policy help to address imbalances in employment opportunity etc.

7.1              We answer, no. 

7.2              The preferred option – see our replies to questions 4 & 6.

7.3              Findings of community involvement –the Issues and Options Consultation – officer responses (Responses) says that:

“The regeneration of South Bristol has been identified as a priority by the Bristol Partnership and it is therefore considered appropriate that it is included as a key issue in the Core Strategy. It should be noted that economic regeneration of other parts of Bristol are also considered important and sought through the council’s commitment to mixed and Balanced and Sustainable Communities. The Preferred Options also identifies need for regeneration of other parts of the city, including the Northern Arc and Inner City/Easton (the other regeneration areas).”

7.4              The Response to the July, Issues and Options Consultation Paper (the Response) included many responses that criticised the City’s proposal to concentrate development on south Bristol.  Many respondents sought a more even handed approach to regeneration throughout the City.  Why has the Paper only quoted the Bristol Partnership and suppressed the contrary opinions? 

7.5              Alternative options – our answer to question 6 is an alternative option.  We said in our response to the issues and options consultation:

“This option (the south Bristol, Preferred 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.”

7.6     The Paper at paragraph 5.11 says:

“Further work on South Bristol with significant community involvement, will identify the precise extent of regeneration opportunities in the area.”

To invest all regeneration in one area will increase the opposition in that area whilst causing disappointment to the residents of the other regeneration areas.  

7.6              Evidence to support the alternative option - the City’s evidence shows that economic deprivation is as acute in the other regeneration areas as it is in South Bristol.  This Black and Ethnic Minority Housing Needs Study, supports this view.  The other regeneration areas are as extensive as the South Bristol regeneration area.  The Paper refers to no evidence to show the ability of any regeneration area to absorb new housing. 

7.7              The Paper gives no reason to reject the alternative option.  The grounds probably appear in the Officers’ comments in the Response, they say:

“Constraint on major development opportunities elsewhere may be necessary to enable focussed regeneration in South Bristol. Extent of constraint will depend on the overall housing target for Bristol in the adopted Regional Spatial Strategy. However, it should be noted that economic regeneration of other parts of Bristol is also considered important and will be sought through the Core Strategy.”

7.8              Lack of Sustainability Appraisal – The Paper sends the public to read the Sustainability Assessment (SA); which is a separate document.  Other LPAs adopt a more public friendly approach.  They include quotations from their SA in their consultations.  They follow the example of the model Core Strategy included in “Core Strategy Guidance” published by the Planning Advisory Service.  The model regularly quotes from the (SA) to validate the preferred options.  This is more effective public involvement.

7.9              The lack of any reference to the SA to support the preferred option of massive regeneration in a single area of the City and the redirection of development from other regeneration areas is unsound. 

7.10          What is the City’s holding of development land in the South Bristol, regeneration area?  The public will be concerned to know about the reinvestment of the money generated from the sale of the City’s land assets and the destination of the proceeds of sale.

7.11          The Paper is not fit for the purpose of the community involvement because the community cannot make an informed choice from the information that it presents.  The Paper does not contain a reasoned justification for the Preferred Option or a reasoned justification to reject alternative options.  The Paper fails to show that the Preferred Option is sustainable.

 

This policy should be substituted for BSC01:  1        The City recognises Bristol’s housing needs and will work with partners to provide a mix of housing of type, size and tenure that is affordable and accessible.  The City will direct development to these areas to promote regeneration. The areas should be specified.  The descriptions, “northern arc”, “inner city / east side” and “south Bristol” are too vague.  2        The City will, with the support of community involvement regenerate these areas to narrow the economic and social differences between them and the remainder of the City.   3        Regeneration will include improvement to the economic and social infrastructure to enhance the distinct character of each of the regeneration areas. 4        The City will direct development to urban sites before it permits new urban extensions. 5        The City will jointly with North Somerset plan a self-contained urban village to the south west of the City with a public transport base.

 

Q 8    Does the Core Policy set out all the main elements needed to achieve the economic, social and physical regeneration of Bristol?

8.1     Unless the Paper is legible within its own “four corners” it cannot be sound for community involvement.  We refer to the separate schedule of authorities and soundness tests that are attached to this response.

8.2              The RSS proposes significant development within Bristol and to the south west of the City over the next 20 years.  The successful delivery of this growth is dependent on the provision of adequate transport infrastructure. The availability and quality of existing transport links play a key role in deciding where development takes place.  The economic strength of the City and the quality of life it has to offer depend on the accessibility, speed, quality and cost of transport facilities.  These are constrained by the capacity of the infrastructure they use and by social, environmental and health considerations such as safety, atmospheric pollution, noise, vibration and separation of mutually dependent facilities by busy transport corridors.  National estimates suggest that, if unrestrained, road traffic will grow in Bristol by up to 50% by 2016 and 70% by 2026 reflecting anticipated changes in population and incomes.   Significant transport infrastructure must be provided in order to deliver the sustainable growth that is required.

8.3              Within the last 20 years there has been a significant increase in traffic capacity achieved mainly by increasing the efficiency of the road network, junction improvements and traffic management.  The capacity of the highway network has now reached a point where further improvements in capacity cannot be easily achieved without damaging the local distinctiveness and heritage of the City, air quality and the living environment.   The planned south Bristol link road will attract more traffic into the central area.

8.4              Pages 18 & 19 that precede BSC01 fail, in our view, adequately to recognise and address the significant traffic implications the development in south Bristol and in North Somerset will produce, which includes access to the M5.  The City and North Somerset must consider rapid mass passenger transit systems if the City plans to continue to promote new commercial development in the City Centre (BCS02) and major new residential development in south Bristol and North Somerset.  A rail link with a Park & Ride at Portishead would have a major impact on traffic through the western part of the City.  The alternative is that car journeys will continue to increase.

8.5              This Preferred Spatial Strategy Options covers a very wide area that contains many distinct character areas that have different resources and needs.  There is high risk that when it is examined, the submission version of the Core Strategy will fail the soundness test unless there is significant elaboration of these extensive proposals.  

Q 9    Are there other strategic elements that should be included?

9.1              We answer, yes.

9.2              There is no reference to the SWRSS’s policy for North Somerset to plan a new settlement of about 9,000 houses near the south west of Bristol.  Neither Bristol’s nor North Somerset’s Core Strategy consultations mention any joint study or planning.  The new settlement will be intimately linked with Bristol.  It will have a major effect on the needs and resources of south Bristol. 

9.3              South Bristol is too large an area for to be included within a single area action plan.  The City should consider, with the community, whether there is a need for a number of Area Action Plans in respect of the areas described in BCS01. 

9.4              Community involvement will publicise the widely held belief that developers have bought or have options to buy large areas of Green Belt beyond Bristol’s south west urban boundary.  Past experience causes widespread concern that the imprecisely defined proposals for south Bristol will generate further urban sprawl.  Ashton will extend to the proposed urban extension into the new North Somerset settlement.  Volume house builders will continue business as usual.  That means

(i)           that land to use for infrastructure and mixed-uses that is necessary to create a sustainable community will compete at a disadvantage to the developers’ financial priority of house building.  

(ii)          Volume house builders will build the lowest dwelling per hectare density that the LPA will accept to build standard pattern houses.

(iii)         There will be fragmented negotiation in respect of each planning application to secure affordable housing and section 106 money to fund infrastructure.

9.5     The Commission for Architecture and the Built Environment’s (CABE) Housing audit: “Assessing the design quality of new housing in the East Midlands, West Midlands and the South West February 2007” crystallises this pessimism.  The Audit criticised developers’ low design standards and the ability of LPAs, in most of the examples, to achieve attractive spatial and house design.  The Core Strategy should acknowledge the problems caused by the development of the "Northern fringe".  It should expressly state how the proposed regeneration / new mixed-use development in south Bristol will avoid a similar debacle in this huge, proposed development area.  It would strengthen the Core Strategy if it states that the dynamism of the local economy gives City the opportunity to negotiate with developers from a position of strength. 

Q 10  How can the Council involve the community to help deliver the economic, social and physical regeneration of South Bristol?

10.1          The revised Statement of Community Involvement (SCI) provides the protocol.  The Bristol Neighbourhood Planning Network offers the City easy access to communities who wish to be consulted.  Most established local amenity or planning associations are either members or associated with BNPN. 

10.2          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. 

10.3          Planning Policy Statement 12 says at paragraph 3.3

“Local planning authorities should continue to involve the community throughout the process of preparing local development documents and should tailor the techniques to engage the appropriate parts of the community at the various stages.”

10.4          There are lessons to be learnt from the recent consultation about the replacement of PRC homes at Sea Mills.  The public exhibition showed traditional drawings.  It failed to use modern methods such as CAD perspectives or photomontages to show how the suburb would appear following redevelopment.  Developers routinely use these visual tools. 

10.5          The City should, as soon as possible, set up a group to prepare Area Action Plans for regeneration / development areas.  Each group must include Councillors and local community groups. 

10.6          We endorse and adopt the extended answer to this question made in the Hartcliffe & Withywood Community Partnership’s response. 

Q 11  Does the proposed Core Policy set out all the main elements needed to enable the growth of the City Centre?

11.1    We answer, no, the Core Policy is inadequate. 

11.2    We are disappointed with this section.  The inference is that the preferred option is business as usual.  The City must build on the excellent start it has made with Millennium Square and other Millennium Mile developments such as the restored Queen’s Square.  The rivers, the floating harbour and its architectural heritage are Bristol’s greatest assets.  The centres of Birmingham, Manchester and Liverpool are examples of regeneration that includes pedestrianisation and the development of waterways.  Traffic management is central to the quality of life for in the Centre of the City.

11.3    In our response to the Issues and Options Paper – July 2007 we said:

“We note that the Paper does not include any specific references to the development of the waterways.  The Harbour identifies Bristol in the public mind and makes it special.  The whole central area should have a masterplan.  The Harbour should be at the centre of the Masterplan to create a regional capital worthy of international interest.”

11.4    The Paper appears to offer only generic terms to analyse the City’s heritage.  It must not let slip the opportunity to promote itself as a centre of commerce and culture and entertainment - a city where people want to work, live and visit. 

Q 12  Are there other strategic elements that should be included?

12.1            The Core Strategy must identify the City Centre’s separate character areas.  It should say where major schemes could develop.  We have only three Supplementary Planning Documents (SPD) SPD3 (Redcliffe), SPD8 (Nelson Street) and the Temple Meads Area Plan.  The Centre itself and the Clare Street, Corn Street and Castle Park form an axis of major areas for improvement and enhancement that would attract investment.

12.2            The Paper does not identify major planning problems that affect the Centre, which include:

·               The need to give pedestrians priority in parts of the Central area.  Successful pedestrian prioritisation schemes can be seen in Oxford and other cities in Britain and on the Continent.

·               The need to evaluate mass-transit options to link commercial areas, the Harbour, which now has a substantial residential population to the inner suburbs and the three transport hubs - Centre, Bus Station and Temple Meads.

·               The need to improve the street scene and to manage the 24 hour economy, which currently disfigures the Centre at week-ends.

·               The disadvantage of the concentration of tiny, City Centre flats which will fail to produce sustainable communities.  Many of these developments fail to achieve PPS3 design standards and promote an active street.

12.3            The City promoted the Broadmead, Business Improvement District, which is a successful vehicle upon which to build community involvement to transform the central area. 

12.4            The promotion of mixed use development should include the provision of supporting social and community provision and green infrastructure as elsewhere.  The increase in the number of residential units in the city centre should be limited by the provision of sufficient open space to the emerging Bristol Standard under the Parks and Green Spaces strategy. 

12.5            Environmental quality of city centre development must be included.  This may imply protection of existing green space and trees to improve air quality and to mitigate against climate change.

12.6            The answer to paragraph 8.1 lists necessary, additional information, which applies to this option. 

 

BCS02 - Alternative Policy for the City Centre To prepare a City Centre area action plan to provide guidance on creation of a regional city centre of international importance and interest; a place where people wish to work live and visit. Development will include: ·         The promotion of the City as a centre of commerce, leisure, education and culture.  This will be achieved through of mixed-use development that will include 150,000 sq. m. of new office floorspace, retail and leisure and 7,500 new homes. ·         The promotion of the rivers, canal, the Harbour and the City’s architectural heritage and the regeneration of the City’s gateways of Old Market, Stokes Croft and Cumberland Basin. ·         Traffic management to reduce congestion and to improve the pedestrian access and the quality of urban life and to improve air quality. ·         The promotion of a study of the means to promote a rapid transport system to link the, City Centre, the Harbour, the transport hubs, the inner suburbs and Bristol International Airport.

 

Redevelopment of part of St. Philips 

Q 13  Does the proposed Core Policy set out all the main elements needed to achieve the part redevelopment of St. Philips etc

13.1    We answer, yes.

13.2          St. Philips is a large area.  With a brief physical description of the area the proposal would be less general and more spatially specific.

13.3          Residents in the Easton and Lawrence Hill areas say that the City should, as soon as possible, set up a group to prepare Area Action Plans for regeneration / development areas.  The group must include Councillors and local community groups.   

Q 14  Are there other strategic elements that should be included?

14.1          We answer, yes.

14.2          Easton and Lawrence Hill residents propose that the Area Action Group should consider plans to promote and regenerate the Feeder Canal to make it the hub and spirit of the area.  Our answer to question 11 about the Floating Harbour and the River Avon applies equally to the Feeder canal.  Valencia and Adelaide each show examples of successful, river inspired linear parks.

14.3          There is currently no convenient modal interchange between the railway and inter City and local buses.  There is the opportunity in St. Philips to bring the three transport hubs of Temple Meads, the Bus Station and the Centre together.

14.4          The answer to paragraph 8.1 lists necessary, additional information, which applies to this option. 

 

BCS03 - Alternative Policy for St. Philips To prepare an area action plan for St. Philips north of the Feeder Canal (this area to be defined by named, street boundaries) in order to provide an integrated and sustainable framework for the delivery of strategic mixed use development, which will include: ·         1,000 homes (or more). ·         The promotion of knowledge based employment in the science, technology and research. ·         Support for social and community infrastructure. ·         Support for a green infrastructure that will promote and regenerate the Feeder Canal to make it the hub and spirit of the area. ·         To promote a study of the possibility of a transport hub to permit the interchange of passengers of the railway and inter City and local buses.

 

Economic, social and physical regeneration of the Northern Arc etc. 

Q 15  Should the Council prepare an Area Action Plan for part of St. Philips?

15.1    We answer, yes.

15.2    St. Phillips is an area where the City proposes to direct significant mixed-use, higher-density development in the early part of the Plan Period.  The City must consider in consultation with its community, whether it would benefit from a single Area Action Plan.   

Q 16 Does the proposed Core Policy set out all the main elements needed to achieve the regeneration of the Northern Arc etc?

16.1          We answer, no.

16.2          The Paper includes no strategic elements.  The proposals are vague and aspirational.  Policy BSC04 fails to show how higher policy is to be applied.  It is not sound to name generic areas and propose to “Identify further opportunities for comprehensive regeneration.”  The northern Arc and Inner City / East cover vast areas of the City that contain communities of diverse social and economic backgrounds.  Early in the plan period the Core Strategy must propose an urban design study to identify the capacity of potential regeneration areas to absorb additional housing and to which it can direct significant, mixed-use higher-density development.

16.3          The Paper does not give reasons why it is not possible to advance specific proposals in respect of regeneration areas other than South Bristol.  If it is because the City lacks evidence, it should say so.

 

BCS04 - Alternative Policy for the regeneration areas Early in the plan period the City will initiate an urban design study to identify the capacity of potential regeneration areas to absorb additional housing and to which it can direct significant, mixed-use higher-density development. To prepare an area action plan for each of the regeneration areas (these to be specified by district) in order to provide for their comprehensive regeneration and in particular: ·             To direct mixed-use development to areas where the need for regeneration is identified so as to enhance the distinct character of an area. ·             Housing density should be at the highest level that can be achieved without detriment to the character and quality of each character area. ·             To support and improve the physical and social infrastructure of regenerated areas and to improve access by sustainable transport to minimise the need to travel.

 

Q 17  Are there other strategic elements that should be included?

17.1    We answer, yes.

17.2    The proposals in the Core Strategy are too vague to describe as a policy.  There is no time scale.  Will there be specific regeneration policies for the other regeneration areas before 2016?  We infer that the City will direct development away from the other regeneration areas to south Bristol.  How did the City apply the SA to this, business as usual option?  What was the answer?  We believe this policy to be unsound and unsustainable. 

17.3    The answer to paragraph 8.1 lists necessary, additional information, which applies to this option.   

Q 18  Should the Council prepare Area Action Plans for these areas?

18.1          We answer, yes.

18.2          The City must consider in consultation with its community in each of the districts of the other regeneration areas whether they would benefit from a separate single Area Action Plan. 

Extensions to the Urban Area / Green Belt -  

Q 19  Does the proposed Core Policy set out the main elements needed to deliver growth in extension to the urban area of Bristol? 

19.1          We answer, no. 

19.2          The Panel Report that followed the Examination in Public reported that SWRSS policy did not require green field development to be sequential to intra-city regeneration.  Development inside the City and in urban extensions was said to be complementary.  The practical effect of the South Bristol preferred option coupled with the South West Bristol urban extension will exclude the regeneration of other areas.

19.3          It is to be expected that the urban extension will have a lower density than the increased density of regenerated areas.  It will be more difficult and more expensive to build the physical and social infrastructure in an urban extension than it would be in the other regeneration areas.

19.4          It is a truism that an urban extension is further away from centres of employment and recreation than the established, other regeneration areas.  It is less likely an urban extension would have access to frequent public transport than would regeneration areas which would offer a higher density.  The preferred option will generate more private car use contrary to the overarching principle.

19.5          The Paper does not quote the SA’s findings when it was applied to the policy to permit urban extensions simultaneously with inner City regeneration.  Did it offer any proposals to mitigate the effect of the SWRSS, EiP report?

19.6          Supporting social and community provision and green infrastructure should be included 

Q 20  Are there other strategic elements that should be included?

20.1    We answer, yes.

20.2    Policy should indicate that, subject to the annual monitoring of the Housing and Employment Land Availability and Needs Studies, the City will not permit urban extensions and the release of Green Belt land until later in the Plan Period.  In the context of the extensive development proposals within the City this restraint, during the early years of the plan, upon simultaneous internal and external development, does not conflict with RSS policy.

20.3    We propose a policy that supports an all-encompassing approach to the management of land on the City’s urban fringe.  Some of this land is untidy and underused and has lost its amenity value.  The policy must assume the principle that any significant change must be considered in the context of the whole urban fringe.  This will include the Green Structure Network and the need to provide recreational uses, such as playing fields.  Of particular importance is the preservation of the landscape role of Bristol’s green southern and western views.

 

BCS05 - Alternative Policy for extension to the urban area / green belt 1          To regenerate the City’s suburbs, the City will direct development to previously developed land within the urban area.  When Housing and Employment Land Availability and Needs Studies show that the City’s development cannot be sustained within the urban area it will permit green field land through sustainable urban extensions. 2          Green field development will not be permitted unless plans are in place to provide the necessary, sustainable physical and social infrastructure for each and every development. 3          To minimise the need for car travel, any green field development must have good access by foot or cycle or public transport to a range of employment, shopping, education, health care, social care, leisure and community facilities, and be within sustainable public transport corridors 4          The City will prepare a joint area action plan with North Somerset to plan a new settlement in North Somerset. 5          Any green field development must ensure that the landscape views from the City to the south and the south west are preserved.

 

Q 21 Should the Council prepare joint Area Action Plans for Urban Extensions?

21.1          We answer, yes. 

21.2          The City and North Somerset must plan the necessary physical and social infrastructure to regenerate areas of south Bristol and the new, North Somerset settlement whose residents will use the City’s infrastructure irrespective of the administrative boundary. 

21.2    To prevent urban sprawl and to preserve Bristol green views, open space between settlements must be preserved.  The City must support promote Option B of North Somerset’s October 2007, Core Strategy consultation.  The City must use its best endeavours to ensure that a new settlement is close to good rail and other public transport.  None of us want a repeat of the "Northern fringe" debacle.  Such a new settlement would not depend on the construction of the south Bristol ring road to which the Society and many other community groups object because, among other issues, it would generate additional traffic. 

21.3    The City should use its best endeavours to ensure that the assembly of land, master planning, planning control, negotiation of infrastructure and S106 funding and production of building design codes, are promoted and managed through a dedicated public-sector-led North Somerset Urban Village Company.   

Avonmouth / Bristol Port 

Q 22  Does the proposed Core Policy set out all the main elements needed to support the future growth of Avonmouth / Bristol Port?

22.1          We answer, yes.   

Q 23  Are there other strategic elements that should be included?

23.1    We answer, yes.

23.2    The majority of Portishead’s residents depend on Bristol economically and socially.  Avonmouth with Portishead are a single employment zone that spans the Avon.  The City should consider with North Somerset and South Gloucestershire whether it is desirable socially, economically and environmentally to develop a Joint Area Action Plan.  Commuter traffic from North Somerset has increased with the development of Portishead and will increase further with the development of the new settlement.  Cooperation is required to introduce traffic management and to improve sustainable public transport. 

Preferred development principles (policies 7 to 23) 

Urban design, built environment and urban character Policies 

Q 24 Do the proposed Core Policies set out all the main elements needed to achieve high quality urban design and place shaping?

24.1    We answer, no.

24.2    The preferred option states general principle without local application.  Bristol has distinct areas and neighbourhoods.  The Preferred Development Option should include reference to the need for development to recognise and protect and promote distinct “urban villages” as neighbourhoods of mixed uses, quality design and local activity and sociability. 

24.3    The preferred option should promote a study to identify areas

(i)                       to be preserved,

(ii)                      suitable for “business as usual” that is, incremental development,

(iii)                     areas that are suitable of not suitable for tall buildings, i.e. buildings above 6 floors and

(iv)                   areas where positive measures are necessary to secure enhancement or regeneration and which could benefit from plans that range from Area Action Plans to Design Codes to make them more attractive for their residents.

24.4          It is important to promote a policy that makes possible judgments about areas that have capacity to absorb and benefit from increases to their density.

24.5          The Paper should give greater guidance about the standards that the City intends to enforce to drive up the quality of design.  This advice must apply to the City’s Highway Department.  The current development of the former airport at Hengrove has provoked widespread criticism.  CABE, in its housing audit said that residential developments dominated by highways standards lead to uninteresting urban design.

 

BCS07 - Alternative Policy to describe the expected quality of urban design Development must: 1.      Ensure that any addition to or alteration to the public realm, shows the highest standard of urban design and architectural quality.  2.      Respond positively to the distinct characters of the City’s different areas and accommodates the needs of all members of the community. 3.      Protect all strategically or historically important views of and within the City and enhances those views through good urban design and architecture. To achieve high quality urban design, architecture and place making the City will: 1.                     Require masterplans / design codes for major sites. 2.                     Set out detailed standards in the Development Control Policies DPD.  This will include reference to best practice, including CABE Buildings for Life, Lifetime Home Standards and DfT / DCLG Manual for Streets. 3.                     Refer major applications to CABE South West Design Review Panel and smaller applications to Bristol Urban Design Forum. 4.                     Develop updated urban design guidance to include in an SPD. 5.                     Highways design must accommodate the demands of planning design.

 

Q 25  Are there other strategic elements that should be included?

25.1    We answer, yes.

25.2    BCS08 is not strong enough.  The Response (to the Issues and Options Consultation) showed that residents highly value the historic environment, the Harbour and the views into and out of the City.  Bristol has an inheritance of neglect of its architectural heritage.  The Preferred Option must give a high priority to the preservation and enhancement of all buildings of note or local importance, listed buildings, parks and conservation areas.  The City must positively promote the reuse of historic or significant local buildings that have become redundant.

25.3    Our answer at paragraph 8.1 that suggests necessary, additional information applies to this option.   

BCS08 - Alternative Policy for Conservation Areas and historic environment Development: must recognise Bristol’s historic built environment is an asset of regional and national importance. ·         must enhance the City’s built heritage through positive measures      and must maintain the local character of an area. must seek new roles for significant or historic buildings and groups of buildings. ·         must enhance the historic character of the City.  Development that harms the landscape of the City or which does not enhance a Conservation Area will not be permitted.  Highways work must respond positively to the historic fabric of the City and aid to enhance the design quality of places and spaces.

 

Climate change, energy and waste 

Q 26  Do the proposed Core Policies set out all the main elements needed to help reduce etc

In respect of BCS09

26.1    We answer, no.

26.2          Why should the requirement for sustainability statements be restricted to major developments?  These requirements should apply to all development that exceeds 10 or more houses or 1,000m2 commercial space.  To apply the standards only to major developments would mean that a large proportion of developments would not achieve the standard.

26.3          Requiring ‘minimum’ standards - BREEAM and similar appraisal systems do not have ‘minimum standards’.  These must be set by Bristol with, for example, ‘Excellent’ required under BREEAM.  There should be a commitment by Bristol to match the highest standards set by other authorities.

26.4          A defect that we suggest is inherent in BCS09 is that it addresses only new build.  In 2026 it is probable that more than 90% of homes in Bristol will have been built pre-2006.  There is Government evidence to show that existing housing stock uses energy inefficiently.  The existing stock, both domestic and commercial presents a challenge to the City’s aim to improve energy efficiency.