We got some bad news for Christmas, unfortunately.
We need your urgent help – we have until the 7th January 2019 to make our voices heard. Members, friends and anyone who values what we do and what we stand for, please submit a response!
The West of England (WoE) local authorities are looking at sites for a Park & Ride on the M32. They say they found 17 possible sites, but they have already ruled out 16 of them. The only site left on their list is Sims Hill (see p.40-42 in the WoE Joint Spatial Plan Emerging Findings Transport Report document). Our “Big Field” that you can see from the M32 is named as unlucky “option 13”. They want to kick us out and pave us over!
The public consultation is open until 7th January 2019. We are asking friends, members and networks to please send in a response. At the end of this page is a longer and extremely helpful response drafted by the Bristol Food Network (thank you BFN!) with more detailed information.
How to respond
This is the most straightforward way we have found (!) to manage the West of England website.
- Register as a respondent with WoE consultation – sorry, but they won’t let you respond otherwise.
- WECA will send you an email with a link to the site to set your password (check your junk mail folder if you don’t get an email).
- Go back to this page and click “add comment” then “continue” to log in and add your comment.
- Tell them your thoughts on the suggestion of building a car park on the Sims Hill field, and try to name the document where the Sims Hill proposal is mentioned: WED 008 Emerging Findings Transport Report (Nov 2018) pp.40-42
Also tell your local Councillor
Please also copy your text and email your local councillor(s) (and the Bristol Mayor if you are a Bristol resident, by copying in email@example.com ) telling them that you are trying to respond to this consultation – they will be able to influence the decisions of the West of England, so it’s vital they hear from their constituents.
You could mention…
Download a Word doc with a draft text here: Sims Hill letter draft Dec 2018
- Bristol City Council are supposed to be prioritising local food production. The Council have said in their own documents that they want to prioritise “space for local food production within the city.” (p.73, Bristol Development Framework Core Strategy). In WoE proposals on housing, they apply the objective of minimising the loss of productive land, especially best and most versatile agricultural land. We think this objective definitely applies to Sims Hill.
- Sims Hill is more than just a farm. We run a veg box scheme that feeds over 80 local households in Bristol and South Gloucestershire. We run a highly valued weekly community group at the Sims Hill Community Food Centre for people experiencing food poverty and social isolation. We employ local people in valued jobs. We work with our nearest primary school and other community groups to give young people access to outdoor space and understand where their food comes from. We provide volunteering experience in long-term and short-term roles, giving a wide range of people access food, land and wellbeing.
- Sims Hill is in the top 3% of agricultural land in the whole of the UK. Sims Hill Shared Harvest and the rest of the Blue Finger Alliance are committed to maintaining agricultural land that can feed local people, support local wildlife and improve our environment. The land proposed by WoE is classified as “Grade 1 Agricultural land,” which means it is classified within the top 3% of all agricultural land in the whole of the UK as the “best and most versatile”. This land has feeding the people of Bristol and South Gloucestershire for hundreds of years. In the document, WECA acknowledge “public preference for alternative land uses” for the Stapleton Allotments as a reason that site is unsuitable. The same applies to Sims Hill.
- There are other sites available. Even though we don’t want to become a car park, we also support attempts to reduce the traffic and congestion in Bristol – we are affected by the traffic, noise and pollution as much as anyone! But we believe there are more suitable sites outside the Blue Finger Alliance area, nearer the M4, that have not been shortlisted or considered in this plan and that should have been.
If you have any questions, please get in touch with our interim Chair, Corra Boushel corra.boushel[@]hotmail.co.uk
Bristol Food Network’s draft response
Our great supporters at the Bristol Food Network have been drafting a response as well. Here’s their thoughts, which give more detail on the points mentioned above.
I/We object to the proposed siting of a Park & Ride at Sims Hill, or any of the existing “best and most versatile land” within the Blue Finger Alliance identified area that is currently used for smallholdings, allotments or other agricultural purposes. We believe the Blue Finger land should be retained for agricultural uses and should not be used for transport or housing.
- 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 two 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. WECA and the local authorities have a duty to cooperate on identifying sites.
- Failure to consistently apply sustainability objectives.
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 Joint Spatial Plan, which in terms of environmental concerns have only been assessed for visual impact and flood risk.
- 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.
- 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.
6.2.4 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: Recreational value; Historic significance; 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.
6.2.5 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.
- 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.