Please take a couple of minutes to respond to this consultation and save Sims Hill from the tarmac!
Closing date: Monday 7 January
The West of England authorities are looking at sites for a Park & Ride, south of J1 on the M32. They say they are looking at 17 possible sites, but they have already ruled-out 16 of them. The one site they haven’t ruled out is currently occupied by the Community Supported Agriculture project of Sims Hill Shared Harvest, and by surrounding fields and woodland. The land is in the Green Belt. It’s also part of Bristol’s Blue Finger – our Grade 1 Best and Most Versatile agricultural land that once held the historic market gardens which fed the city.
Comments must be made by Monday 7 January
Responding to papers:
WED 007 Transport Topic Paper 8 (Nov 2018)
WED 008 Emerging Findings Transport Report (Nov 2018) pp.40-42
Below is the response which has been submitted by Bristol Food Network. Please feel free to use our arguments, but don’t forget to mention why Sims Hill is important to you.
You might also like to contact your local Councillors and MPs: https://www.writetothem.com/
the West of England Mayor, Tim Bowles
and Bristol’s Mayor, Marvin Rees, who has the power to stop the scheme in its tracks:
We object to the proposed siting of a Park & Ride at Sims Hill. Any of the existing Best and Most Versatile land within the ‘Blue Finger’ currently used for smallholdings, allotments or other agricultural purposes should be retained for agricultural uses and should not be used for transport or housing.
1. The proposed Park & Ride site for the M32 area has been moved.
In the Emerging Spatial Strategy Transport Topic Paper from November 2016 and in most subsequent maps, the “indicative” P&R for the M32 has always been shown either at the junction of the M32 and M4 or to the north of the M4. By the time of the publication of the Joint Spatial Plan in November 2017, the P&R has become a “New P&R site south of M32 J1 to intercept trips into Bristol”.
Of the 17 sites considered in the Emerging Findings Transport Report, it appears that only 2 sites north of the M4 had been considered. It is generally assumed that this is because South Gloucestershire Council will not release/identify land within their authority area for a P&R, leaving potential sites predominantly in Bristol. There is much more land available to the north of the M4 than there is to the south. We would like to see what sites have been identified and ruled-out in that area. The WoE local authorities have a duty to cooperate on identifying sites.
2. Failure to consistently apply sustainability objectives.
The WoE have applied the following Sustainability objectives to their assessment of Strategic Development Locations for housing:
4d. Promote the conservation and wise use of land, maximising the re-use of previously developed land.
4e. Minimise the loss of productive land, especially best and most versatile agricultural land.
These objectives don’t appear to have been applied to transport proposals within the JSP, which in terms of environmental concerns have only been assessed for visual impact and flood risk.
3. Inconsistency in assessing P&R sites.
One of the identified sites – Stapleton Smallholdings – has been “Discounted due to size constraints and public preference for alternative land uses (allotments).” Stapleton allotments were earmarked for a P&R site (in Bristol’s soon-to-be-replaced Site Allocations document) which was intended to link-in with new the Metrobus infrastructure near Stoke Lane. This P&R proposal received massive public opposition, culminating in the occupation of the contested land by protesters. At the time, and in order to end the protest, promises were made that the P&R at Stapleton allotments would be removed from the Site Allocations document and that the remaining high quality agricultural land in that part of the city (known as the Blue Finger) would be protected against future developments. The “public preference for alternative land uses” is not restricted to the Stapleton Smallholdings but applies to ALL BCC-owned smallholdings and allotment land within the Blue Finger – on both sides of the M32. Similarly, Eastville Park has been discounted as “not expected to be supported by the public”. This argument applies equally at Sims Hill.
4. Failure to acknowledge Bristol’s emerging Local Plan.
The JSP Transport papers have not acknowledged Bristol’s emerging Local Plan, and the special protection which is intended for the Blue Finger land. This seeks to protect all BCC-owned land within Stapleton Allotments and Holdings for agricultural uses and to recognise its “special importance for food growing and community use”. Again, we note the duty to cooperate amongst the WoE authorities, and the lack of consideration of how this policy should extend over authority boundaries.
p.56 (which is p.62 of the PDF) – 6.2.5 special designation for Stapleton Allotments and Holdings
Proposal HW 3: Specially Protected Local Green Space
Land identified as Specially Protected Local Green Space will be permanently retained as open space. Development which would result in harm to the land’s open character or role will not be permitted.
Ancillary development of a proportional scale may be acceptable where it directly supports the open space function of the land.
Specially protected Local Green Space is a designation set out in national planning policy. Its role is to protect open spaces that are demonstrably special to the local community and which need to be kept open permanently. Local Green Spaces are identified based upon five criteria of local significance relating to:
Richness of wildlife;
Beauty and tranquillity.
Local Green Spaces are also required to be demonstrably special to the community they serve and offer a unique and irreplaceable provision to that community.
In Bristol, the types of open space that fall into the category of specially protected Local Green Space are considered to include:
Traditional, multi-functional parks and recreational estates;
Land designated as Town and Village Greens and Common Land;
Designated Local Nature Reserves;
Stapleton Allotments and Holdings (see Proposal RES 5).
Proposal RES 5 p.62 (p.68 of the PDF):
Proposal RES 5: Stapleton Allotments and Holdings
The Stapleton allotments and holdings will be recognised in the local plan and designated as specially protected Local Green Space in recognition of its special importance for food growing and community use. Developments which are inconsistent with this role will not be permitted.
The current designation of the land safeguarding it for transport infrastructure will be removed.
5. Inadequate desk-top assessment.
The Emerging Findings Transport Report has included a “Desk-based assessment of environmental, social and economic impacts, and value for money of the options”. This survey has not been thorough in identifying sitting tenants and potential problems around existing tenancies. There is no mention in the document that the Sims Hill site is currently occupied by Sims Hill Shared Harvest CSA, which has a lease on the land till 2021. Nor is there any mention that the surrounding fields are farmed under a 3-generation hereditary tenancy arrangement.