Grounds you can use to object

The number one thing we are asking people to do is comment on the planning application.

The legal minimum 21-day window expired on 11th August 2021, but you can still make objections.

You can easily comment by clicking here. But what do you say? A 6,000-word blog (here) goes into a lot of detail about how best to object to planning applications. This shorter blog makes the same points. Here are two key ideas.

  1. Objections have more effect if a number of people object. Your voice counts. Please object and then get other people to do the same.
  2. Objectors should use their own words. Don’t just copy and paste. Pick the points you care about – then describe them yourself.

1. The key point: This proposed development should be turned down as the site is green belt land. Green belt land is protected by national and local planning frameworks. For much more information on the status of this land as green belt, see here.

Why else should this development be turned down?

2. Green belt land should not be built on when there are brownfield sites and previously developed land (PDL) available. Bristol currently has over 200 brownfield sites available. As we come out of the pandemic many more previously developed sites could become available and be redeveloped for housing.

Moreover, as recently as 6th July 2021 the Mayor confirmed: “We now have a healthy stock of 12,750 homes in planning permissions“. This is the number of housing units that have been granted planning permission by the Local Planning Authority but not built. With such a “healthy stock” already in place, building on green belt land should not take place.

3. Bristol says it is a leading voice in response to the climate and ecological emergencies. The One City plan (third iteration) talks about the improved provision of green spaces across the city and the role they can play in increased physical activity, reducing obesity and health inequalities. This proposal destroys green belt land and removes green space.

4. Nature and wildlife
Ashton Vale Fields is a Site of Nature Conservation Interest (SNCI). Importantly, the SNCI is bigger than the Town and Village Green (below). The SNCI does not stop at the metrobus route. It extends into the proposed site of development (see here). The main protection currently proposed is only: “a 5 m offset between the development and the SNCI” (C3.41). This isn’t good enough.

The Portishead Branch Line Preliminary Environmental Information Report (vol 4), described Ashton Vale Fields as “an important bird site” (4-12). It noted: “The site’s mosaic of wet grassland, open water, ditches, hedgerows and scrub is particularly important for wintering and breeding wildfowl and waders”.

The current planning documents note: Potential indirect effects include disturbance to breeding and wintering birds during construction”. And that the SNCI could experience “effects” as a result of the Proposed Development during the construction and operational phase. Building Longmoor Village will not protect nature.

As well as birds, submitted documents note the unconfirmed presence on-site of various species, including some protected ones, such as: great crested newts, water voles, otters, bats, badgers, hazel dormice and hedgehogs.

Documents, including the Environmental Impact Assessment Scoping Report, keep noting that further ecological surveys are recommended, and required in advance of determining the planning application. It is not clear if these wider surveys have been carried out. Please contact us if you can find them on the planning portal.

The entire development site is also a designated “Wildlife Corridor” (see here). The site should not be built on, especially as other local wildlife corridors have been reduced through housing development. Specifically the Alderman Moore allotments (now Ashton Rise).

5. The site is an important amenity to the local community. The proposal should be turned down as it would stop the health and wellbeing benefits associated with the site which include walking, dog walking, access to nature and other activities.

The last time development was proposed on this site (Nov. 2009), objections were lengthy and progressed all the way up to judicial review. As part of this process Barrister Ross Crail conducted an inquiry that recommended that all of the lands should be registered as a Town or Village Green (TVG). This was because local people had used the space for leisure for at least twenty years. The report can be downloaded here or here. It is worth scanning the report to appreciate the long history of local people using the site (warning: the report is 276 pages long).

While the council chose not to designate this piece of land as a TVG, the report and its recommendations demonstrate the significant historical and current amenity use of the land to the local population.

Taken with point 4 above, aside from its green belt status, under Bristol Core Strategy Policy BCS9, the proposed development site represents part of the “Strategic Green Infrastructure Network” for Bristol. Indeed the site is marked as such in diagram 4.9.1. of the Core Strategy (page 79).

6. The proposal should be turned down because it does not contain enough affordable homes. The planning application notes that it will deliver up to 510 residential units of which only 30% (153) will be affordable. The Mayor’s 2021 manifesto pledged 2,000 homes a year, with 1,000 of them affordable: a 50% rate.

Recent housing developments in South Bristol have shown how developers can do even better.

Old Brewery, Ashton Gate. 107 homes – 100% affordable.
Totterdown Bridge. 152 homes – 100% affordable.
Off Winterstoke Road. 67 homes – 100% affordable.

No one doubts that Bristol needs more “affordable” housing, but 30% is not enough.

7. More pressure on schools and doctors
During the consultation, local residents in Ashton Vale expressed concerns about the increased pressure on schools and doctors in the local area. Increasing homes in the area by more than 500 dwellings (1,500+ residents), will put further pressure on local services, negatively impacting the local residential amenities.

8. “Five stories high”
The current application is an “outline proposal” only, so it lacks a lot of detail. However, if approved up to 17% of buildings will be 5 stories high or 18m tall. The rest up to 3 stories or 11m. The visual impact of the development will be significant for those living in the local area. It will be out of scale and out of character compared to the existing developments in the local area. Local houses may face overlooking and loss of privacy issues or even shading / loss of daylight. The loss of current views for existing properties will adversely affect the residential amenity of the neighbourhood and the open outlook of the neighbourhood will be lost.

9. The planning application argues that building on this land is necessary to “unlock” the Ashton Gate Sporting Quarter (AGSQ). Indeed, this unlocking argument is thought to be exceptional enough to warrant building on the green belt.

A document submitted during planning notes: “The anticipated value of Longmoor with the benefit of planning permission, is £24.1 million. This accounts for 19% of the total costs of construction of the development at AGSQ (£126.5m).”

SAVE is not against the sporting quarter. Nor the founder of Bristol Sport, Steve Lansdown. However, if the unlocking potential of this development is cited as being exceptional, then it must be noted that Steve Lansdown is a billionaire, estimated in the Sunday Times Rich List 2021 (no.124) as being worth 1.365 billion. His wealth has increased by £15 million in the past year alone. For a man with such increasing wealth, any argument that green belt land needs to be built on in order that he can make a mere £24.1 million more seems spurious.

10. Flooding
The National Planning Policy Framework says: “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future). Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere.” (point 155).

The site is at risk of flooding*, with some areas in Flood Zones 3 and 2 it would seem that development of this land would increase the flood risk either here or elsewhere in the local area. Recent extreme weather events should be telling us that we cannot ignore flood risks. Moreover, in their comments on the application, the environment agency objected to the plans on flood risk grounds (27th July 2021).

* click on the link above and see all the different flood risks this site is at risk of. Risk of flooding from: i. rivers or the sea, ii. surface water, iii. reservoirs (?). We had to research the last one. Apparently, if the Barrow Tanks on the way to the airport, fail or overflow, then the area of land designated to be inundated with water includes this site.

11. Landfill
The site used to be used for landfill. There are concerns about pollution issues both during and after potential building works on old landfill sites (BBC news story).

The Geoenvironmental and Geotechnical Desk Survey in the planning portal concludes: “Overall, it is considered likely that significant soil/ groundwater contamination is present and the associated potential risks from contaminated land for the proposed development are anticipated to be moderate” (p.40). These include risks such as: ingestion and inhalation of contaminated dust and soils and vapours, ingestion of homegrown produce from contaminated soils, uptake of contaminants in plants, inhalation of fibres, particularly asbestos. These do not sound like great risks for future residents to be exposed to without considerable remediation of the site.

12. ETM Recycling

The proposed site borders an existing ETM Recycling Centre. It is already there. But building homes next to it has implications in terms of odour, dust and noise for the new housing. In terms of noise, past planning permissions have been given to ETM based on noise assessments with residential properties more than 250 metres away. And more recently, even behind a sound reduction barrier.

WHO recommends that steady, continuous noise should not exceed 55 dB in outdoor living areas (balconies, terraces etc.), with moderate annoyance, being noise above 50 dB (LAeq). In ETMs separate recent planning application (application: 21/01169/X; doc: 21_01169_X-PART_1_-_NOISE___VIBRATION_MANAGEMENT_PLAN-2901469.pdf; table 6.1), noise levels were found to be at 59.9 at a point 45 metres away from ETM, actually on the proposed site for Longmoor Village. This seems to be above the annoying threshold level of noise. The outline planning application seems to propose to only deal with these noise levels through the use of thick glass in windows. Worryingly, this may limit the potential of people in these homes to have the enjoyment of outdoor living space close to their homes, or indeed opening the windows in their homes.