So why is it that so much of our informal green spaces are still being lost, and so many of our trees continue to be felled?
Is the BCC Development Office blocking Climate and Environmental Action?
A clue to this came out of a recent planning application to build a 4-storey block of flats in St Paul’s, in a street with one of the highest illegal levels of pollution in Bristol, above recommended noise levels, in a known high flood risk area and on land thought to be contaminated. It was shown that the planned development would increase pollution and noise levels. Furthermore, in an area with one of the lowest tree density in Bristol, five mature maple trees were to be felled, removing the last mitigation for noise, pollution and flooding in the street. The trees are on the very edge of the development site and could therefore have been retained, readily complying with BCS9 which states “Individual green assets should be retained wherever possible and integrated into new development”.
Bristol’s Planning policies are contained in two main documents:
- The Bristol Development Framework Core Strategy (the BCS policies).
- The Site Allocations and Development Management Policies (the DM policies).
These are supplemented by the Planning Obligations Supplementary Planning Document. All were variously adopted and implemented by the Council between 2011 and 2014.
Despite contravening core strategy planning policies on green infrastructure (BCS9, DM15), pollution (BCS23, DM33), climate change (BCS13), flood risk (BCS16), noise (BCS23, DM35) and health (DM14), the Development Office did everything in its power to promote and advocate this development.
The reasons for this became clearer when officers were asked during the Planning process specifically why they supported a development which breached so many core policies aimed at protecting the health of citizens, the environment and the City’s crucial green infrastructure.
The Head of Development Management responded, “With regard to this application, the policy aims of the Core Strategy could be seen as the delivery of housing (BCS5), including affordable housing (BCS17)”. Further, “Loss of green infrastructure will only be acceptable where it is…… necessary, on balance, to achieve the policy aims of the Core Strategy”.
The statement effectively says that, whilst the need for new and affordable houses remains, BCS5 and BCS17 can override other policies including those mentioned above. Thus, green infrastructure that could have been retained is ignored, pollution and noise levels above legal limits are permitted, and the worsening health of residents would be tolerated. This position seems to be contrary to that previously held, with development under BCS5 and BCS17 needing to be also in compliance with the other core policies. As there will always be a need for new homes and affordable homes, the concern is that all other policies can be set aside indefinitely.
We would suggest that BCC Development Office interpretation is in contravention of the National Planning Policy Framework (NPPF) which states that: “the purpose of the planning system is to contribute to the achievement of sustainable development (remember that phrase), including “an environmental objective” – to contribute to protecting and enhancing our natural environment, including helping to improve biodiversity, mitigating and adapting to climate change and moving to a low carbon economy”.
So how has the BCC Development Office responded to BCC’s Climate and Ecological declarations?
The Development Office was also asked how implementation of planning policies had been influenced by the Climate and Ecological Emergencies. Their response was:
“Whilst Climate and Ecological Emergencies have been declared by the Council, the Bristol Local Plan has not been fully reviewed in the light of these and the policies referred to remain unchanged. Changes to Local Plan policies would have to balance the objectives of the respective declarations with the requirement to deliver sustainable development for the city”.
By “balance”, it seems they may effectively mean “ignore”. Clearly their definition of sustainable development is somewhat different to that defined in the NPPF, with no intrinsic “environmental objective”, and, as one Councillor on the Committee remarked, the development will “lead to poorer people having shorter lifespans”. Unpacking their response still further, the implication is that there are currently no core policies in place to implement the Climate and Ecological emergencies. As described above, this is not true. Were BCS9, DM15, BCS23, DM33, BCS13, BCS16, DM35 and DM14 to be applied as intended in the NPPF, there would be sufficient policy support at least for the principles of the two emergency declarations.
Is this being led by bureaucratic or political decision making?
It is not clear why the Development Office has taken this position, but there are two possibilities that should be of concern:
- The Development Office is acting contrary to the aspiration of the City’s political leaders.
- Senior Council politicians who have made much political capital from the highly praised environmental declarations, have at the same time permitted, or perhaps even encouraged, Council Officers to disregard existing planning policies that would otherwise enable implementation of these declarations.
Thus, selective policy compliance allows development of second-rate housing in a race for quantity over quality.
It seems that Bristol City Council are choosing to emphasise some core strategic policies aimed at hastening house building, whilst demoting other core strategic policies aimed at protecting public health, green infrastructure, air quality and the environment. This is a recipe for slum development, and we deserve to know whether these decisions are being taken at a political or bureaucratic level.
Professor John Tarlton.