Response to Bristol Plan

Response to the Bristol Local Plan Review

The Westbury on Trym Society celebrated its 50th anniversary earlier this year and whilst its primary interest in this consultation relates to the character and well being of Westbury on Trym, both within the designated conservation area, which is one of the oldest in Bristol, and outside, it is also mindful of the wider impacts on the city.
We welcome progress on the Local Plan Review and we congratulate the City’s Planning Department on Local Plan review so far and thank all who contributed to this comprehensive and detailed piece of work. Because of the detail, we have found understanding some sections easier than others. We appreciate that planning policy and guidance is constantly changing making plan preparation an extremely difficult technical process. However, it is somewhat confusing to the layperson as to what this consultation is about. It refers to changes that are being proposed to earlier draft documents without specifying what these are. We consider that it would have been far better to have seen a more comprehensive document so that the new proposal and policies could be seen in a clearer context, especially as the consultation draft states that the whole plan will have to be re-written. We also have concerns due to the difficulty that consultees will have in trying to understand the document due to the technical details which it contains, which seem to be more relevant to a Supplementary planning document.
The lay person will be bewildered and we fear will give up trying to comment - even to those of us accustomed to using planning ‘speak’ and perusing advisory documents it has proved a daunting task. The language used in some places is very technical and not comprehensible to the layperson. The result will be that a minority, elite public will send in their thoughts but that it will bypass the average citizen - hardly a democratic exercise. When the plan is finally published we suggest that it is accompanied by short, coherent summaries for each section to encourage wider public awareness and participation? Plans/layouts and aerial photographs are very helpful to locate which part of Bristol is under scrutiny and its relationship to the whole of the City. This is particularly relevant when viewing shopping centres due for renewal in line with the new ’15 minute’ neighbourhoods concept and for understanding those areas where residential building at greater densities is proposed.
Finally, rather than attempting to comment on every aspect, we have looked at those chapters and aspects that are most appropriate to this part of Bristol, where we live and have understanding of our own local needs and problems, especially the need to improve our local shopping centre and above all our dire traffic and parking problems. Thus the Society's representations are structured as follows:
Housing Need and Requirement; Net Zero and Climate; Biodiversity; Food Sustainability; Shopping; and Design.

4. Housing Need and Requirement
We support the conclusions of the Opinion Research Services assessment of housing need that the annual need for 3,376 dwellings to be unrealistic. The conclusions of the housing need assessment appear to be in line with para. 61 of the NPPF, which we understand is in the process of further review in the light of issues such as those raised in this city.

Accordingly, we do not support the level of provision of housing in accordance with the standard calculation method. Bristol does not have the land supply, being more tightly constrained in its administrative area than almost any city of its type. The Society supports the arguments set out in the report for reduced provision. Even accommodating the reduced level of housing proposed, the Local Plan Review is already advocating development of Green belt land and significant densification of suburban and other areas. The loss of Green belt land will affect the character of the city and will undoubtedly generate opposition from the areas affected. There is also a threat to the character of the city through densification to the densities proposed. if not undertaken well. The growth in population from the increase in housing will not be accompanied by an increase in significant open space. The open spaces that we have will be used ever more intensively. Many of the City's Parks are heavily used especially in the summer and they are not adequately funded. Accordingly, the growth in the city's population will add further stress on its open spaces. This will need addressing.

It is not clear from the document what consideration has been given to the provision of elderly persons housing and purpose built student accommodation in coming to the conclusion, as provision of such accommodation will make housing that would otherwise be occupied by these groups available.

6. Net Zero and Climate
The Society consider that this chapter of the document will need substantial revision as it is too detailed and involves a dramatic change which the development industry will need to adapt to, bearing in mind that most developments in this area are undertaken by small contractors. The Society accepts that climate change is a serious issue that needs consideration in the planning process, but the change from the current guidance to net zero needs to be incremental. The effect could be to prevent development that is needed coming forward. Much of the required housing development will be carried out by small developers who will find the policies too complex. The level of detail into which the policy goes will take a significant amount of time to assess during the consideration of an application.

This is a very technical chapter, much of which would be better contained within a Supplementary Planning Document. The Society considers that policies NZC2 and NZC3 are too detailed and lengthy. They should be reduced and guidance provided in a separate technical document. By way of example, policy NZC1 includes an expectation to achieve a water efficiency standard. This should not be addressed in planning policy as this cannot be enforced and water use depends on the behaviour of the building occupants. Rates for energy offsetting, suggested in NZC2 will need to be reconsidered over time.

Policy NZC4: Adaptation
This policy needs to make specific reference to the word “gardens”, not just vague “green infrastructure”, particularly at site level. Gardens provide efficient use of land in carbon capture and mitigating urban heat generation. The gardens of suburban areas like Westbury on Trym are a valuable asset in mitigating the effects of climate change. Town centres like that of Westbury on Trym generate considerable heat and carbon loss so the surrounding gardens are vital elements in lessening these effects.

Where para 6.74 (Site level methods for reducing the risk of overheating) refers to “increased vegetation” there should also be a reference to retaining important vegetation, including trees and hedgerows not just increasing it by methods such as green roofs.

7. Biodiversity and Nature Recovery
The policy text in BG1 does refer to retaining important Green Infrastructure, including trees, hedgerows and water features. However, while there is a separate policy on trees, we would like to see more emphasis should be put on hedgerows and urban hedges. BG4 para 7.30 spells out the benefits of trees. But hedgerows are only subsequently mentioned as edible landscapes in 8.20. It is important that the benefits of urban hedges and hedgerows are similarly highlighted.

In areas like Westbury on Trym there are many short lengths of individual garden hedges which link up to form longer “hedgerows”. We suggest adding the text: Urban hedges and hedgerows provide many benefits for both people and wildlife. They offer living space, shelter and food for wildlife, movement corridors for small mammals and navigation aids for bats. Hedgerows absorb noise and pollution from roads and mitigate the effect of high winds. They provide a natural alternative to walls and fences and contribute to a healthy and characterful environment for urban living.

Policy BG4: Trees
We welcome the comprehensive policy on trees, reflecting increased recognition of their importance in national policies. We endorse the provision that replacement trees should be planted as close to the development as possible. However, as noted above we would like to see greater acknowledgement of the value of urban hedgerows, preferably within this policy as they complement the benefits of trees within Green Infrastructure.

7.33 Delete the word “considered”, trees are assets.

Other proposed Green Infrastructure Policies
Explanation 7.40 states that a policy on Development of Private Gardens will be “based on” current policy DM21. Clarification is needed. If alterations and amendments are being included, they should be specified at this stage.

8. Food Sustainability
The Society supports draft policy FS1 relating to allotments. Westbury on Trym is fortunate in having a number of allotments in or close to the village and the Society would like to see other areas having a similar benefit.
We endorse the suggestions for incorporation of land for local food production where feasible - this is redolent of the Garden City movement, where sheltered land for food cultivation and safe, protected play spaces were designed to lie behind the houses themselves.
The Society welcomes and supports draft policy FS2 and is pleased to note that this policy relates to all residential proposals, not just larger developments. The explanation in para 8.29 to policy FS3 should allow for the protection of community gardens where land ownership is not in the hands of the community, but the community wishes to continue their operation

9. Shopping, Services and the Evening Economy
The 2019 draft of the Local Plan Review indicated that the existing Core Strategy and Development Management policies relating to shopping would be retained as they were considered to be flexible in relation to future changes in retailing. The introduction to the November 2022 review refers only to 'a revised network of centres and draft policies to support the diversity of centres and a thriving hospitality economy' It is not clear whether or not the policies proposed in this section are replacing all the policies that were previously said to be retained.
Westbury on Trym as a 'town centre' is in an accessible position but car access will be needed from many parts of the surrounding area because public transport links are only good from a north south direction. The present role of the centre is to provide services to a wide area due to the shops, banks and other services it provides. However, it is vulnerable to changes in retail provision, especially closure of banks - HSBC is closing its branch in Westbury in 2023. We agree that it will be important to manage the proportion of non retail units.
The Society notes the intention, set out in para 9.16, to include a 'vision statement' for each identified shopping centre. The Society is not aware of a vision statement having been prepared for Westbury on Trym. Last year members of the Society attended a Zoom meeting with the council's retail consultants, which considered, amongst other things, retail trends in north west Bristol, but the consultants present seemed to have little local knowledge. Currently there is not an active business association in Westbury. However, the Society endeavours to bring businesses together through its promotion of hanging baskets and flower displays in the village. The Society would wish to be involved in preparing a vision statement but does not have the resources to promote or prepare such a statement on its own and would require assistance to do so.

Policy SSE2: Development in Bristol's Centres
The Society notes and is pleased to see that this includes a section on residential development and agrees that changes of use to residential will not be appropriate in primary shopping areas to protect them from the adverse impacts of 'dead' frontages . However, the General Permitted Development Order will undermine efforts to prevent such changes as it does not recognise any distinction between primary and secondary shopping frontages in permitting changes to residential from town centre uses . The Society considers that withdrawing permitted development rights in certain areas should be explored by the council to counteract the threat from the GDPO.
Another key reason for the decline in many small centres is the high cost of rates for small business enterprise and it is very difficult for small traders to get started these days because of this. Might we urge the Mayor and Council to press the case for reduction of these high rates, with central government?

Policy SSE4:Town Centre First Approach to Development
The Society supports the stated intention of the policy to limit the growth of 'town centre' uses outside shopping areas and the requirements for impact assessments. Notwithstanding the existing policy that seeks to do the same thing, it rarely seems to curtail the spread of the discount retailers outside shopping centres despite the impact that the leakage of expenditure must have on existing centres.
Policy SSE5 Temporary uses in centres
This policy includes the clause that 'Proposals for the temporary use of vacant sites for car-parking will not be acceptable'. The Society sees no justification for a blanket ban on temporary car parking uses. This could support the viability of town centres and improve the environment in surrounding streets where centres have little or no parking. This clause seems to be based on a presumption that it will undermine sustainable travel, which need not be the case and a temporary parking arrangement pending redevelopment could be of assistance to a shopping centre.
While it is clear that Local Plan policies need to encourage walking and cycling, there should be a recognition that there are considerable challenges to the lifestyles of an ageing population in the coming decades. Even the facilities of a 15 minute neighbourhood will be out of reach of those who cannot walk or cycle and those who struggle to use public transport. It is important to retain safe and accessible car parking areas in town centres and local shopping areas, but to ensure that they provide electric vehicle charging facilities, given that electric vehicles will become increasingly predominant.

Policy SSE7: Provision of public toilets
The Society supports this new policy. However, it is ironic that this should be included in the Local Plan after the council has closed most of its public toilets, including those in Westbury and have sold the site without offering any alternative suitable provision.

The reference to the WECA “Place-making Charter” in para 10.2 is pertinent to guiding standards for new developments and large scale housing innovations in the West of England area to which we belong, but not helpful for our own local planning situation.
As a local planning group representing people who live in a suburb with a very strong ‘sense of place’ and history, because Westbury on Trym is older in origin than Bristol itself, dating as it does from its first religious settlement in the 8th century, we do not need assistance in how to construct a community, but rather help to maintain the one that already exists. We have an established and unique identity - as do many of the other ‘village-suburbs’ that encircle the City of Bristol, once having been parts of Gloucestershire or Somerset, such as Kingswood, Frenchay, Brislington and Bishopsworth.
What we do need is help from both planners and developers to enable us to preserve the existing character and functions of our neighbourhoods. Our own planning group is part of a Society set up in 1972 to protect Westbury’s historic landscapes, buildings and patterns of development and to ensure continuation of its many existing amenities.
So we look to this policy document for the next thirteen years of augmentation and remodelling of many areas in Bristol, to help us preserve the best of what we have already, while accepting a share of the redevelopments for much needed housing; that is, where they can be fitted into an area already very densely populated and built on and without any open land - save Canford Park and of course our gardens, which everyone is keen to retain as important green infrastructure for climate change and now home food production too.
In this context we are pleased to read that both latter aspirations fit well into the many statements spread through different chapters of this document - satisfying policies on creation of green space, hedge boundaries for wildlife corridors, planting of trees and retention of open land for relaxation and children’s play. We hope, therefore, that the council will not allow further building on garden plots under the guise of ‘brownfield’ developments!
It is also comforting to read in Chapter 14.5 (Private Outdoor Space) that the plan recognises that “development of new homes intended for long term occupation should incorporate high quality and usable private amenity and play space appropriate to the proposal” and in 14.7 “private outdoor space is to be commended for its contribution to quality and liveability of new housing developments”.
These points endorse our own aspirations for Westbury on Trym exactly and cover problems of land use that have occurred in recent planning applications. So, we welcome indicators that show many familiar policies from the previous Development Management Guidance on Design and Function, will be retained and applaud assurances that communities will now be asked to play a part in determining what is suitable for their particular neighbourhoods. (see 10.3 and 10.5)
The following detailed comments highlight those matters of particular importance for our own area, to which the Society gives enthusiastic support and awaits further detail.

Proposed approach to design: Policy DC A
The commitment in para 10.3 that local planning authorities will be expected to prepare local design guides or codes, that contain ‘detailed design guidance’ and ‘Design Guidance is to be developed in partnership with local communities’ is warmly welcomed.
Another commitment in para 10.5 that Local design guides or codes will build on clear design vision and expectations reflecting local character and responding to local design preferences expressed through community involvement, is again warmly welcomed. However, given the constraints of budgets, workforce and time available is this capable of being realised?
The wording of the Local Character and distinctiveness element of DC A ‘Development proposals which introduce new types of design, scale and form…will be appropriate ‘where it would not be harmful to local character’ is agreed but it depends on subjective opinions from developers and planning officers - and who will be the final judge of what is or is not appropriate? Our opposition to two recent proposals of a major kind, on grounds of their being inimical to the character of their neighbourhoods, were fortunately backed by the decisions of the planning officer, but his judgement could have gone the other way just as easily, decided under delegated powers rather than by a planning committee or inspector.
At para 10.16 reference is made to other proposed design policies to come or building on those existing in the DM guide. We support the retention of:
- Alterations to existing buildings – DM 30
- Refuse provision - DM 32 – very much needed (there have been some disgraceful plans for refuse storage in recent applications in our locality)
- Conservation and the Historic environment – BCS22 and DM 31… crucial guides for our locality
Retained policy BCS22 -all component parts are familiar to all those dealing with local planning applications and we welcome retention.
In terms of residential densities we consider more detail is required and also in respect of ‘Liveability’ in developments, including space standards.

DC B Draft Policy – Advertisements
This policy has implications for both City-wide advertising methods and those occurring in local shopping areas. It is difficult to disagree with any part of it and indeed it may be an awakening to how shabby and aesthetically displeasing many areas of Bristol have become compared to other towns and cities because of crude, random adverts and densities of graffiti.
We support the text of para 10.19 ‘Perceptions of lower levels of visual amenity in any area will not to serve as a benchmark for harmful proposals including increased clutter of adverts.’
Every neighbour hood deserves the right to be smart and visually uplifting – crime and anti-social behaviour are encouraged in areas degraded by defacement of property, overlooked by large advertising hoardings and where no-one appears to care for the public realm.

We welcome the potential restraint on hours of operation and luminance levels in digital adverts in para 10.20. We would like this be applied to shop front facia boards, trades and banks too, as some have become hideously crude and intrusive recently - though this is based on subjective judgements of course!
It would be good if higher standards of taste and discrimination could be introduced for shop facias-including appropriate/more elegant commercial typography. Would planners consider the advice of a typographer to advise on appropriate styles, fonts and colours when applications are made to change a business – so they may enhance public spaces rather than disturb them?

Appendix 3 on Local Design Guidance
It would be difficult to disagree with any of the principles laid out in the chapter on Design Policy and its Appendix 3 on Local Design, except that maybe both are rather too wildly aspirational. We are all aware of the profit motive that is the guiding principle of developers in the recent past of more ordinary economic conditions - but in the present economic crisis, combined with shortages of the best materials and a properly trained labour force in all of building’s many disciplines, it will be unrealistic to imagine that all matters will be accurately observed or reach full realisation.
Nevertheless, it is very encouraging to read of high reaching ideals, in the hope that the standards of planning applications for both architectural form as well as promised functions, will follow the same path and what is achieved may be nearer to the ideal than would otherwise be the case.
We consider these principles will have to be applied on two levels:
Firstly, as required for the further ‘densification’ of the existing ‘urban’ areas of the City, to meet housing needs for those who require or prefer inner city lifestyles and the city's intentions therefore to fit in greater quantities of speciality urban housing blocks and high-rise flats, where entirely new concepts of designs for living will be appropriate - and
Secondly, where increased demand for ‘suburban’ living will continue to require a different policy approach, that is: - one of careful scrutiny of, and a disciplined approach to, individual planning applications for infill housing or, more likely, adaptations to existing stock, in surrounding built up areas where gardens and open spaces still exist, but in diminishing quantity.
While the principles for distinguished and tasteful architecture that complements its surroundings, apply in both cases, the design guidance for ‘suburban’ living has perforce to be different - where dimensions of living space, areas for recreation and leisure and distances to shops - for families and the retired - will inevitably differ from spaces needed by younger, daily employed citizens or students, who relish a nightlife, eating out, clubbing and studying and who have not yet accumulated possessions. Nor do they wish to have the responsibility for gardens and allotments, and have an entirely different pattern of living without daily visits to a park or sports field, which are desirable parts of family life.
Furthermore, when areas of the inner city desperately require new green infra structure of all sorts for health and visual amenity, and especially trees for carbon capture as an antidote to polluted air, which are all listed as design matters, the former small towns and villages that now form suburban Bristol need to have what they already possess left where it is, namely in their gardens and parks!
Existing green features in Bristol’s streets and Parks also need proper maintenance by a well run City Parks department, instead of the widespread neglect that pertains at present and are all likely to deteriorate even further if recent budget proposals for cuts are carried out, while the quality of our open green spaces and woodlands may have to rely on the uncertainties of amateur, voluntary maintenance! Sustaining these design aspects of the ideal ‘green city’ are not addressed at all in this document.
The Westbury on Trym Society considers that future design guidance needs to make clear the distinctions between ‘urban’ and ‘suburban’ lifestyles and their requirements - particularly as these will affect the design and function of new or alternatively, re-development of older properties, in different ways. The term ‘densification’ has varying implications and consequences, according to where it is to happen and the distinctions should be made plain to everyone – especially to potential developers who can and will, use ‘densification’ policies as a catch-all - regardless of where a potential site exists. In our locality applications to increase density of residential living conditions need to be handled with care and the respect due to a conservation area.
We welcome many of the draft policies that have elevation of design standards at their heart - especially for application to our own conservation area and historic surroundings and these are listed (or questioned) under separate points further down.
The appendix appears to repeat much of the content of Chapter 10 but it promises further detail to come and, therefore, it is worth noting those sections of particular interest and importance to ‘village suburbs’ such as ours and other historic districts in wider Bristol.
- ‘Designing House Alterations and Extensions’
- ‘Conservation Area Appraisals’ – we have recently covered Westbury’s conservation area and increased its scope, with assistance of the appropriate City officers - but there is always more to learn and other similar places may need this help in preserving local character.
- ‘Shopfront Guidelines’ – these are of particular importance because the original trading section of our village is dying. Five old shops have been changed to residential recently and have ‘blind’ frontages that are neither one thing or another. In the same part of the original ‘High Street’ there exists a row of elegant but small Victorian shop frontages, deserving of listing, although they are now used as service premises. They nevertheless contribute to the character and ‘visual amenity’ of the village and are a reminder of a more glorious and busy local retail centre in the 19th century. We appreciate the comments elsewhere in the document that residential use above shops must not result in ground floor loss of identity and vibrancy as part of a shopping centre. However, it is difficult to see how this may be achieved if trading has ceased and given permitted development rights.
‘Transport development management guidelines’ – this will be of great interest to Westbury and to other centres trying to preserve their local retail and service economies. We have reached what may be termed ‘peak parking’ in and around our village and in spite of being fortunate in having a car park owned by the City Council, residents, shoppers, business owners and many teachers from five schools, have to fight for on street parking spaces, while the Car Park itself is occupied by many of the patients visiting the Health Centre-albeit short term. Given the high numbers of older people who live locally or visit for banking and other services from surrounding areas, scooter transport is not a viable alternative to car use in the absence of regular and connecting bus services!