Planning and Development

Objection to proposed Retail Development at Ashton Gate (09/03208/P)

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Objection to Planning Application ref 09/03208/P

Retail Development at Ashton Gate

 

submitted by Cllr Charlie Bolton, September 2009

[Most of this objection was written prior to the release of the consultants report on the retail assessment supplied to the council by its independent consultant.]

1. Damage to trade on North St

It is clear that the application makes absolutely no attempt to take into account the impact on North St. it is left out of the calculations, and an assumption is made that it will 'be all right'.

This needs to be seen in the context of

a. the general decline in small traders

A report by the all-party small shops group produced a report highlighting the decline in small traders, and the dangers this poses. It stated that some groups of traders will disappear by 2015.

b. the sheer scale of a Tesco

It is absurd to suggest that siting a £50 million pound store close to a shopping street will simply have no impact on that street

c. There will be a wide range of people who use shops, for different reasons. There are those who have high levels of loyalty. However, there are also those who shop more for convenience. It is this latter group who are most likely to switch their shopping habits from the local high street to Tesco.

d. This situation will be exarcebated if one of the key food retailers is lost. At present, the range of shops is available now (at the Tobacco Factory end of North St) - all within a smaller distance of each other than the typical supermarket. If one of the key shops goes, then the ease with which it is now possible to use North St will reduce, and encourage less loyal shoppers to seek an alternative. This will put further pressure on local shops.

e. It has to be noted that small traders are much more vulnerable than supermarkets. They can not compete on scale.

2. Damage to trade on East St

The report makes claims about the numbers of linked trips to East St from the store. It is interesting to note that this directly contradicts the findings of the councils retail strategy which says (in the shopper survey for Bedminster)

45. The site visits showed that the Asda store on East Street was a well-patronised store with high footfall. The street surveys do not however, pick up high proportions of people shopping in the store. This indicates that shoppers at the Asda store may not subsequently visit the centre.

44. Although the surveys show that some respondents do make linked trips, covering both Bedminster Centre and Asda, it is probable that many do not. It could be inferred, that the lack of quality retail provision in Bedminster, and, or, the poor linkages between the store and town centre is deterring people shopping in Asda from making linked trips.

However, the report claims that 58% of visitors to East St do make linked trips. If these figures are correct, and if it is also correct that a new Tesco will remove a substantial proportion of Asda trade (£9.4m pa). If the figures in the application are correct, this poses a significant threat to the viability of Bedminster Parade and East St - because there will be substantially fewer people to make the linked trips. This could amount to  a drop in footfall of 10s of thousands per year. If the figures are incorrect, it casts doubt on the application as a whole.

3. Too far from local shops to benefit them in any way

The Tesco store will be located some several hundred metres away from the local high street. It seems highly unlikely that anyone will make linked trips from their to North St, and if they do, they will drive. However, the basic fact remains that supermarkets are set up to be driven too.

4. Local pollution impacts due to extra traffic

The new store, if the figures quoted in the application are to be believed, will massively increase the amount of traffic going into the Ashton area, especially Winterstoke Road, Ashton Road, Duckmoor Road but also pervading through to North St and other roads in Ashton and Bedminster. It is likely to add some millions of extra trips per year to the area.

It needs to be noted that the stadium traffic is only moving a short distance away. So all stadium traffic will continue to come to the area, and this needs to be considered in addition to the impact of the store. The effects will be especially pronounced on match days, and, in particular, on big match days.

It should further be noted that the public transport in the area is poor.

This will have impacts in terms of congestion, local pollution impacts and increased CO2 emissions.

There is inadequate public transport to the area at present, and the majority of people come by car. Given that an out-of-centre stadium is set up for car travellers, it is debatable if people would in any case choose to travel on foot.

5. Damage to Greville Smythe park - loss of amenity value/increased in litter

The huge increase in traffic levels is likely to lead to a deterioration in the air quality in Greville Smythe Park. Also, superstores generate a significant amount of litter, which is also likely to negatively impact on the amenity of the park. Traffic levels on Ashton Road will decrease the safety of young people, in particular, making journeys to the park.

6. Defies retail strategy

The Executive summary of the councils retail strategy (http://www.bristol.gov.uk/ccm/content/Council-Democracy/Statistics-Census-Information/citywide-retail-study.en) tells us 'many existing stores will be undertrading compared to national expected levels of turnover' and that 'there will be no capacity for extra trading until 2021 at least'

It goes on to say that at a local level there may be a need for individual cases of need but gives the proviso that these will be where 'it strengthens particular local centres'.

There is no evidence at all to suggest the building of a Tesco will strengthen local centres, and, in fact, there is evidence that it will weaken it.

The strategy goes on to describe Bedminster North St as 'at risk'. It seems curious that it can be possible to further risk a high street which is so described.

The strategy also recognises the importance of 'local independent retailers to the shopping attraction in Bristol'. Again, it would be curious if the council were to promote the exact opposite of independent retailers to the detriment of these independent traders.

7. Increase in CO2 levels/ green city/ CO2 legislation/ councils CO2 strategy

The council is committed to reducing its own emissions by 3% per year. It is now law that Bristol’s emissions be cut by 80% by 2050. There is a motion going to Bristol City Council supporting targets of 40% cuts by 2020.

We have seen that building a Tesco at Ashton Gate will lead to a substantial increase in traffic congestion. It has been shown that it will have poor links by anything other than a car.

It has also been shown that there is no need for it, therefore it will, if built, result in an unnecessary construction (therefore emissions) and result in an additional transportation network to the area caused by the lorries delivering all the food.

Supermarkets have distribution networks which are inefficient (the classic example being raspberries, grown in Scotland, package near Bristol, sold in Scotland). They also have a curious definition of local – so any claims of local food they sell should be considered with care.

The generation of extra journeys of all sorts will therefore significantly worsen Bristol’s carbon footprint.

8. Defies council strategy of getting people to travel by sustainabletransport methods and any sustainable community strategy

The council has recently unanimously adopted the recommendations of the sustainable transport select committee, which is aimed at promoting walking and other forms of sustainable transport. It specifically included a recommendation that a further select committee be set up to look at ways of promoting local high streets.

A supermarket clearly defies this.

It is also clearly absurd to suggest that any sustainable community strategy the council may have can be enhanced by a supermarket which will detract from it.

9. Parking difficulties increase (especially on match days)?

The increases in levels of traffic is likely to increased on road parking in areas where parking is already at a premium. This will obviously be worse on match days.

10. Failure of application to in any way take account of impact on local shops

This has been amply demonstrated in the independent consultants report on the retail assessment

11. Won't create and will probably lose jobs

The assessment also points out that any job claims for a Tesco are spurious and recognises there may be nett loss of jobs. It should be pointed out that any jobs lost in local shops to a supermarket will lead to a further nett loss to the local economy, because of the centralised distribution systems in supermarkets. This is a double whammy to the local economy.

12. Other ways of funding any spending deficit eg Lansdown

It is a mystery as to how the claims that there is a funding gap has been reached. It needs to be proven, otherwise any claim that there will be no stadium without a Tesco must be called into doubt. This is especially the case in view of the flaws in the information supplied by the club in its retail assessment.

Ultimately, if the councillors or council given in to the powerful vested interests, then the council might as well give up and hand the keys of the council house over to those interests.

 

Response to Bristol City Council’s proposed Supplementary Planning Document 5

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Supplementary Planning Document 5

SUSTAINABLE BUILDING DESIGN AND CONSTRUCTION


November 2005

A Response from Bristol Green Parties


1.  SUMMARY

As a statement of principle and a source of suggestions SPD5 is admirable, but we do need far stronger controls if the ambitions behind SPD5 are to be fulfilled.  We cannot leave a sustainable future to chance and to the market.  

If major improvements can’t be made now, we hope that a further consultation, very soon, will be about the high standards that will be a prerequisite for any new development, or major adaptation, that seeks planning permission.  One vital proposal (the Zero Net Carbon Standard) is included here.

We also hope that some land use designations can be relaxed where developers can show that they fully respect the spirit behind the designation – through ‘low visibility’ developments, car-free guarantees etc. that would have a negligible footprint.

2.  THE MYSTERIOUS LIMITS TO THIS CONSULTATION

We understand that SPD5 is in most respects simply an adjustment to planning structures to take account of changes that have been introduced by the Government, particularly the replacement of Local and Structure Plans with Local Development Framework, without making any substantive change to the way the City Council appraises new development proposals.

We do wonder why on earth policy improvements can’t be considered  right now.  In fact the Council’s own “Bristol Local Development Scheme”, which sets out the programme for the Local Plan’s metamorphosis into a Local Development Framework,  seems to suggest that this is the time for review:-

“All policies within the Bristol Local Plan (adopted 1977) will be saved for 3 years. During this period policies will be reviewed and, where appropriate, incorporated into future Local Development Documents”

If it can’t be done now, we hope that SPD5 will quickly be reinvented as planning requirement rather than as planning guidance – and that we’ll have the opportunity to suggest very specific improvements.  In fact one – because it should have been done yesterday – is detailed below.
 
3.  WHY  WE  NEED  HIGHER STANDARDS - NOW

Put simply, we are living so far beyond our means that we cannot sustain today’s patterns of resource use – and here, resource doesn’t just mean raw materials, it means the biosphere on which our quality of life, even life itself, depends.  Climate change is, of course, the obvious example.  So sustainable construction is not just an option, it’s a must.

The good news is that the world has woken up to this, and from the highest level of international government to the most local level of community and enterprise, there is a string of aspirational statements calling for change in the way we do things.

The bad news is that generally that’s all they are.  The city’s current ‘Bristol Sustainable Guide to Construction’, like the proposed SPD5, offers developers good advice and good arguments for better design, and explain why it’s needed – but developers main objectives are economic and most will prioritise the bottom line over and above any non-statutory sustainability wish-list.  The buildings going up today will be standing in twenty, forty, a hundred years time, and they’ll encourage a particular lifestyle:  as things stand, very few fit our picture of how the world should be by then – they’ll be part of the problem, not part of the solution.  

4.  REGULATION – OR PERSUASION?

 It is, of course, an accepted reality that any developer should be subject to particular obligations, (for instance the Building Regulations, or the prescriptive land use designations of the Local Plan)  and the planning system provides the main framework for making sure that happens.  What may be in question is the degree to which local, regional, and national governments should lay down the law about the detail.   We feel confident that the public interest must come first – and that includes the interests of the future generations whose environment is being moulded by the decisions that developers are taking now.  Therefore, we must have very strong planning requirements based on ‘meeting today’s needs without compromising future generations’.   We can’t leave that to the developers.

However, this does not imply that there’s any ‘perfect’ sustainable design to be laid down for any new development, and of course we wouldn’t want to see Bristol or any other authority going down that road.  We need high standards set for (for instance) energy efficiency; but we don’t have to be prescriptive about how it’s to be achieved.

5.  ONE VITAL  REQUIREMENT

If we could commend just one overarching requirement for development in the city, it would be the one developed by Friends of the Earth calling for a Zero net carbon standard.   It appears to meet the recommendations of the Local Governent Association, the Energy Saving Trust, and the Energy Efficiency Partnership for Homes:-

The Council is committed to addressing and reducing the causes of climate change.

To achieve this objective all new development, either new build or conversion, will be required to demonstrate that it does not add any net carbon dioxide emissions over the life-cycle of its operation. Developers may adopt a range of technological approaches to achieve this objective, including:
1)    A zero waste, zero carbon standard (based on the Z-squared approach) for any large scale housing development.
2)    A minimum of EcoHomes ‘Excellent’ or equivalent recognised standard for any housing development of one unit or more.
3)    A minimum of BREEAM ‘Excellent’ for any commercial development.
4)    The development of on-site renewable energy generation capacity.

It will be for the developer to decide which approach is the most appropriate to deliver a zero net carbon standard in their specific proposal. The applicant must demonstrate, through a development appraisal, if the adoption of such an approach results in an undue burden on the viability of the scheme.

In addition, there will be a presumption against any development which results in a significant net increase in carbon dioxide emissions.

It is arguable that such a policy should be included in the LDF’s Core Strategy rather than SPD5, as it impacts not only on Sustainable Construction, but on the ‘Residential Design Guide’ and the ‘Generic Development Control Policies’.   Certainly we would like to see it as a cornerstone of the LDF.

6. PRECEDENTS

Although Bristol has its fair share of initiatives with admirable ‘eco-design’ built in, the city does lack the means to make sure that all development approaches the standards set by the best of those initiatives.   

Some local authorities are currently well ahead of Bristol – for instance Merton, which has succeeded in warding off challenges to its policy of requiring a proportion of on-site renewable energy in significant developments.   North Devon wants to introduce a similar policy – and finds that the Inspector who might have challenged it has come down in favour of strengthening the policy further.  We note that N. Devon is introducing a series of new requirements for developers, over and above minimal standards laid down by government.   Calderdale is following a similar path, as probably many others are doing.   

We see no reason why Bristol shouldn’t  play a part in pushing the boundaries further – as a city that anticipates major growth without making too many compromises to attract it, it’s in a strong position to take a lead in setting very high standards.  That could bring further rewards, if the city can establish itself as a centre of excellence for progressive design.

7.  ONE CASE FOR DEREGULATION

Much of the foregoing suggests that the City Council needs to be more prescriptive if it's to secure improved standards of sustainability in new development.   However, we do feel that in many cases the opportunity for high quality design is being lost.  This is simply because market pressures and land scarcity squeeze out those who would build to a smaller 'community' scale, emphasising designs that consider the ecological impacts of the buildings and of the life-styles of those who occupy them.   

We wonder whether the council could consider relaxing some of the land use policies to permit development of this kind where 'ordinary' development would not be allowed, effectively opening up a market niche for such projects that would not otherwise be viable.   Of course there may be other ways to help achieve this, for instance by adopting policies that would justify sale of land to such 'green' developers at an affordable price, rather than the excessive prices that can be reached in this city because of land scarcity.

......................................



Thanks to the Sustainable City Team for their considerable efforts in raising awareness of SPD5 and their invitation to comment.

For any follow-up, please contact
Peter Goodwin, Bristol Green Party, at
11 Lanesborough Rise, Stockwood, Bristol BS14 8AJ

   

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