Chapter 8: Centres, shopping and the evening economy
Introduction
– Westbury on Trym and the Westbury on Trym Society
Westbury on
Trym is exceptional in Bristol in that retains a unique rural village character
with a shopping centre, the remnants of that which was developed in Victorian
times remains, together with early and later twentieth century developments.
Large parts of the village centre form part of the Westbury on Trym
conservation area, one of the first to be designated in
The Westbury
on Trym Society was established in 1972 originally
to look after the amenities, landscape and historic settings of this 1300 year
old village
and is thus now over 50
years old. In conjunction with its concern for the amenity of the village, for
a number of years the Society has been responsible for organising the plant and
floral displays in the centre of Westbury on Trym, with the financial support
of local residents and businesses. These displays help to brighten up and
enhance the environment of the village and, we believe, help to attract
visitors to the village.
The Society
has had a close relationship with businesses in the village centre through its
work and its campaigning, but an active business association does not presently
exist and hence the Society is making submissions in respect of the proposed
chapter of the Local plan Review and policies on Centres, shopping and the
evening economy.
General
The Society
considers that the chapter on Centres, shopping and the evening economy will
not be effective, is not sufficiently positive and elements are unjustified.
This may in part be due to the inadequacies of the evidence base.
This sets
the tone of the chapter and suggests that
The Society
does not consider that the chapter reflects the evidence and recommendations of
the Evidence Base – the Bristol Local Centres Study (November 2023).
Furthermore, in relation to Westbury on Trym, we have found significant flaws
in the assessment of the vacancy rate and composition of the floorspace of the
village in 2022 and the situation in January 2024 is very much different to
that in 2022 with a much higher vacancy rate. We very much suspect that the
other town centres will have experienced similar increase in vacancy rates.
To explain
this concern, we have reworked table 2 of Appendix 4 of Nexus Planning – Centre
Viability Report, BAS Consultancy ...
Table 2
(p139 Westbury on Trym Healthcheck) Re-interpreted
|
GOAD Category |
Units Jan 2022 – Nexus Planning |
Actual Units Jan 2022 - WoTSoC |
Actual Units Jan 2024 |
Units (%) Jan 2022- Nexus Planning |
Units (%) Jan 2022- WoTSoC |
Units (%) Jan 2024- WoTSoC |
|
Comparison |
24 |
26 |
24 |
27.9 |
27.9 |
25.8 |
|
Convenience |
9 |
9 |
9 |
10.5 |
9.7 |
9.7 |
|
Financial & Business Service |
15 |
14 |
13 |
17.4 |
15.1 |
14.0 |
|
Leisure Service |
14 |
13 |
14 |
16.3 |
14.0 |
15.0 |
|
Retail Service |
20 |
21 |
21 |
23.3 |
23.6 |
22.6 |
|
Vacant |
4 |
9 |
12 |
4.7 |
9.7 |
12.9 |
|
TOTAL |
86 |
93 |
93 |
100 |
100 |
100 |
The reason
for the difference between the Nexus Planning survey of units in Jan 2022 and
our re-working arises for the following reasons:
· The Nexus table fails to account for
the following vacant units in 2022– the former Post Office, High Street
(ref. 1 on the attached plan); former Vanilla Gifts (47 High Street, ref 2);
vacant units formerly occupied by PDSA and Woods estate agents 28-34 High
Street (refs 3&4); unit 1, 68 Westbury Hill now occupied by Domino’s pizza
(previously Johnson’s Dry Cleaning, ref 5).
· We classify Bristol Locksmiths (ref
6) given its retail sales and shop display, as retail not Financial &
Business services and the survey fails to identify A&J Shoe Repairs at
27 High Street as a retail unit (a subdivision of Patco, ref 7). We consider
these to be both comparison goods units.
· The survey also fails to identify
Westbury Smiles dental practice at
· The table also includes as a leisure
unit the former Royal British Legion club. This was not a ground floor use, but
was upstairs to the rear of the High Street and in any event was closed in
January 2022 and will not be reopening.
Accordingly, there were 93 units not 86 at the time of the
2022 survey. With 9 of these units being vacant, the vacancy rate was 9.7%,
over twice the 4.7% set out in the Bristol Local Centres study healthcheck.
This gives a quite misleading picture of the viability and vitality of Westbury
on Trym town centre. This belies the statement in para 11.45 that Westbury on
Trym appears to have fared relatively well following Covid-19.
Turning to the current situation, there are still 93 units.
One identified as vacant in 2022 (British raj restaurant) has been converted to
residential (ref 10), while a new unit has been built as part of the
redevelopment of
Changes since 2022 involve:
· Closure of 3 Financial Services
outlets (
· Closure of 2 Comparison goods outlets (Kitchens Direct and Fitz
Woodburners & Stoves) – both vacant.
· Opening of 2 Leisure services in units vacant in Jan 2022
(Domino’s and Goldfinch) and closure of the White Horse pub (leisure
unit).
There are
thus 3 further vacant units since January 2022, increasing the percentage of
vacant units to 12.9%, quite a change from the apparently very favourable
figure of 4.7% assumed in the Evidence Base. Furthermore, Barclays Bank is
closing in February 2024, resulting in the loss of the three of the ‘big four’
banks in the village. The financial and business service sector is no longer ‘anchored
by three (sic) retail banks, Lloyds, NatWest and HSBC as stated on p143
of appendix 5 of the Nexus Planning evidence base’.
The Society
organised a survey of users of the Westbury Hill car park in June 2023, which
ascertained that banking was the prime purpose of their visit to
Westbury on Trym for 24.6% of respondents. Accordingly, the loss of these banks
– and likely the future loss of Lloyds bank will be a big blow to business in
the village.
The council
has also resolved that the currently free to use council owned car park will be
subject to charging at £1 per hour. This together with the impact of on-line
shopping and Covid-19 makes the Society very concerned as to Westbury’s future
as a shopping centre. The impact of on-line and Covid-19 is common to all the
If the
experience of the other shopping centres in
The Westbury
on Trym Society is, therefore, concerned that there is little positive in the
policy proposals contained in the chapter on centres. Policy SSE4 Town centre
first approach to development is a positive step, but other policies do not
help and need to go further.
Vision Statements
The previous
draft of this chapter which was consulted on by the council in November 2023
stated at para 9.5 that ‘A vision statement about each of the identified
centres will be included in the next version of the local plan’. The
Evidence base makes recommendations as to possible ways of encouraging the use
of the town centres in
In respect
of Westbury on Trym, the table of recommendations suggests at point 2 that it ‘is
considered to be a suitable centre for a ‘Community Improvement District’, a
self-sufficient business and resident partnership to help develop local vision,
public realm improvements, events and other activities, dialogue with the
council and community owned businesses.’
We welcome
this idea and whilst we do not consider the recommendations to be anything but
preliminary, we consider that the recommendations should be considered by the
relevant parties.
Council
policy to assist its town and district centres is not being supported by the
council’s resolution to charge the users of all its remaining district car
parks, which are currently free, and which serve various
The text of
the ‘Centres, shopping and evening economy’ chapter should refer to the
Evidence base findings. It should be specific that the council will work with
relevant organisations, such as ourselves, to promote activity within the town
centres, as set out in the recommendations. Otherwise potentially important
initiatives to promote town centres will be lost in the depths of the Bristol
Local Centres study, which is a massive document – nearly 1300 pages long.
Article 4
Directions in town centres
The multifarious
uses that are now included in the new Use Class E makes it difficult for
planning authorities to control changes of use of retail units in shopping
centres. Policy SSE1 includes the text ‘Active
ground floor uses will be maintained and enhanced throughout the centres’.
However, in the light of the extent of class E these words are meaningless.
At para
11.56 of the Evidence base, the study notes the importance of Article 4
Directions being imposed in appropriate circumstances to control changes of use
in town centres.
At para
11.59 the Bristol Local centres study notes ‘Suitable circumstances for the
use of Article 4 directions include the protection of town centres, as a July
2021 Written Ministerial Statement noted at Paragraph 53. Taken together, it is
clear than an Article 4 direction applied to a town centre could support and
protect the ongoing vitality and viability of the centre, and could provide
local authorities a greater level of control in the context of increasing
permitted development rights and the introduction of Class E’.
In addition
to the flexibility of use in town centres that Class E gives, there is a
further permitted development right to change the use of a retail unit to
residential, subject to a limited prior approval procedure.
Despite the
comments as to the use of Article 4 Directions in the study, the use of Article
4 Directions as a policy tool is not referred to at all in the Publication
Local Plan chapter on Centres, shopping and the evening economy. The text at
para 8.22 merely states ‘it is considered important to future viability and
viability to manage the proportion of non-retail uses in the primary shopping
areas to ensure that other uses support and do not dominate the primary retail
function of the area.’
The Plan
gives no credible indication as to how this might be achieved and makes no
mention of restricting conversion of retail and other town centre uses to
residential through the use of the General Permitted Development Order.
Protecting the core of a shopping centre from loss of key retail facilities is
now established as justification for issuing an Article 4 direction, as pointed
out in para 11.57 of the Evidence base document.
We consider
that there needs to be a policy stating that the council will seek to use
Article 4 Directions in primary shopping areas to protect the vitality and
viability of a high street or town centre against the adverse impacts of
changes of use, both within use class E and changes of use from class E to
residential.
Town
Centre and Westbury Primary Shopping Area
The Local
centres Study and the Policies map propose no alteration to Westbury on Trym’s
Primary Shopping Area and town centre boundary. We consider that the town
centre boundary on the Proposals Map is too widely drawn in the north of the
centre.
The town
centre boundary extends to land behind
This area
should be removed from the town centre due to land use changes in the past few
years. To the rear of
Trym Lodge,
is set back from the street and is operating as a flexible office space and due
its listed status potential changes of use will be limited. 1-5 Passage Road,
formerly a restaurant and offices have all been converted to residential use
following receipt of planning permissions granted since 2019 and therefore should
be removed from the town centre designation.
Furthermore, service vehicle access is not easy to these premises. Our proposed boundary change is shown below...
This policy includes the clause that 'Proposals for the temporary
use of vacant sites for car-parking will not be acceptable'. The Society
sees no justification for a blanket ban on temporary car parking uses in local
centres. The environment of many local centres is adversely affected by
on-street parking and businesses often consider that their trade is hampered by
a lack of suitable car parking. This is
a common theme of the Local centres Study conclusions on the centres it
reviews.
Car parking, albeit temporary in nature could support the viability of
town centres and improve the environment in surrounding streets, where centres
have little or no parking. This clause
seems to be based on a presumption that any parking provision will undermine
sustainable travel. Public transport has continued to deteriorate in Bristol
post Covid making modal change to public transport extremely difficult to
achieve. Temporary car parks need not harm sustainable travel and a temporary
parking arrangement pending redevelopment could be of assistance to a shopping
centre and remove unwanted on street parking. As far as sustainable travel is
concerned, it cannot be expected that the local elderly population will be
using e-scooters and bikes.
While
it is clear that Local Plan policies need to encourage walking and cycling,
there should be a recognition that there are considerable challenges to the
lifestyles of an ageing population in the coming decades. Even the facilities
of a 15 minute neighbourhood will be out of reach of those who cannot walk or
cycle and those who struggle to use public transport. Westbury on Trym has an
ageing population. It is important to retain safe and accessible car parking
areas in town centres and local shopping areas, but to ensure that they provide
electric vehicle charging facilities, given that electric vehicles will become
increasingly predominant.
Policy SSE7:
Provision of Public Toilets
The Westbury
on Trym Society finds this policy somewhat ironic as the council has closed all
its public conveniences including the ones in the High Street, Westbury on
Trym. That said we agree with the policy in principle. However, as written it
expects far too much of developers.
The wording
of the development states that ‘Major developments that are open to the
public’ are expected to provide both toilets, including disabled toilets and
‘Changing Places’ toilets.
Town
Centre and Westbury Primary Shopping Area
The Local
centres Study and the Policies map propose no alteration to Westbury on Trym’s
Primary Shopping Area and town centre boundary. We consider that the town
centre boundary on the Proposals Map is too widely drawn in the north of the
centre.
The town
centre boundary extends to land behind 55-73 High Street, includes Trym Lodge,
a grade II listed building with a freestanding more modern building behind its
rear car park. It also includes the former British Raj restaurant (1/3 Passage
Road) and two former office units (5 Passage Road).
This area
should be removed from the town centre due to land use changes in the past few
years. To the rear of 55-73 High Street open land is now occupied by a recent
compact residential development.
Trym Lodge,
is set back from the street and is operating as a flexible office space and due
its listed status potential changes of use will be limited. 1-5 Passage Road,
formerly a restaurant and offices have all been converted to residential use
following receipt of planning permissions granted since 2019 and therefore
should be removed from the town centre designation. Furthermore, service vehicle access is not
easy to these premises. Our proposed
boundary change is shown below...
Development
Strategy and Tall Buildings
Para 3.3
says ‘To boost housing supply the plan has a special focus on urban living –
the creation of characterful urban areas where people can live, work and
socialise, relying on sustainable transport’.
There seems
to be a contradiction between the urban living approach, including the
encouragement of tall buildings in Bristol, traditionally a city of low rise
buildings, and design policies which expects development to ‘contribute
positively to local character and distinctiveness’ (policy DPM1). Until
recently tall buildings were previously identified as being in excess of 6
storeys. The definition of a Tall Building now has risen to 10 storeys, as set
out para 13.1.26, part of the explanation to policy DC2: Tall Buildings.
There has been
disquiet amongst amenity societies and the Civic Society as to the application
of the ‘Urban Living’ concept for Bristol. This has meant an exceptional number
of very tall buildings being foisted on the city, the design of which has not
been considered to be ‘high quality design’ as required by DC2.
The development
strategy proposals set out a number of areas where very high density
development can be expected – the City Centre, Temple Quarter, St Philip’s
Marsh, Western Harbour and the Frome Gateway (policies DC1, DC1A, DC2, DC3,DC4
& DC5).
The words ‘Tall
buildings in the right setting and of the right design may be appropriate’
appear in the policies in respect of development of these areas. However, we
have seen a number of tall buildings where the subjective judgement of the city
council has not matched that of the local population. Furthermore, the numbers
of dwellings expected in areas where there is requirement to re-provide
employment space means that there will be limited opportunities to do this as
well as to provide the substantial additional housing numbers. We consider that
this will lead to more emphasis on building tall and on siting such buildings
randomly where opportunities are provided. Previous guidance on tall buildings
in Bristol identified suitable locations. Anywhere else the onus was very
definitely for the developer to justify more than 6 storeys.
We have
already forgotten the disasters that have occurred following the high-rise boom
of the 1960s and 70s. High rise is not suited to family living in the UK to say
nothing of the concerns that high rise has caused. It is unlikely to be the
choice of families seeking social housing and we wonder how the issue of high
maintenance charges on social landlords can be overcome.
The current
Mayor of Bristol has pushed through an agenda for building very tall buildings
in and around the centre of Bristol. We believe the Publication draft has been
pushed through while the Mayor remains in office. For example, there is no
evidence of the Duty to Co-operate with neighbouring authorities having been
given serious consideration. The draft expects the authorities to agree to
provide a significant part of Bristol’s housing need. We note, however, that
North Somerset Council, which is at the same stage in its Plan preparation has
issued a ‘Duty to Co-operate Statement of Compliance’ which advises that
North Somerset Council asked Bristol City Council whether it could accommodate
some of its housing provision!
The strategy
should recognise that there are large areas of Bristol, particularly the inner
and outer suburbs where densification is likely to be harmful to the character
of those areas. No account is taken of
the contribution that is made to the historicity of both central Bristol and
its many ‘suburban villages’. We consider that at para 3.3, the Plan should
state its intention to preserve the importance and character of these parts of
the city.
Biodiversity
and Green Infrastructure
BG4 Trees
The Society
welcomes the inclusion of this policy in the Local Plan.
The Society
would like to see reference to veteran trees and areas of ancient woodland to
be identified on the interactive Proposals Map.
BG6:
Private Gardens
This policy
aiming to restrict the development of private gardens is carried forward from
the council’s Development Management Policies. This policy now sits within the
chapter on Biodiversity and Green Infrastructure.
The Society
supports the policy, but considers that the ‘important contribution to the
city’s green infrastructure’ referred to in para 9.1.45 is a key consideration for this policy,
which is surprisingly missing from the current wording given the policy being
within the green infrastructure chapter.
We note that
policy DC1 Liveability in residential development including space standards,
aspect and private outdoor space, contains the following words in relation to
private outdoor space for new dwellings. ‘The development of new homes
intended for permanent or long-term occupation (generally those within use
Class C3) will be expected to incorporate high quality safe and usable private
amenity and play space’.
Existing
family homes in the suburbs of Bristol contribute very significantly to green
infrastructure and its beneficial effects on air quality, provide spaces for
wild life, vegetable production and most particularly play space for children
and general family amenity - that should be 'usable'. Suburban gardens should be protected from
further development for housing except where it can be implemented without
reducing gardens to unusable spaces. Given the need to support biodiversity,
green infrastructure and reduce flood risk, gardens can play a significant
positive role in these matters.
We consider
that the first part of policy BG6 should be re-worded as follows:
Development
involving the loss of gardens will not be permitted unless:
i The
proposal would represent a more efficient and effective use of land at a
location where higher densities are appropriate and would meet the objectives
of other Plan policies including liveability, biodiversity, green
infrastructure and flood risk and water management.
Housing Policies
Policy H10 Planning for Traveller Sites
An issue
that has arisen in recent years is not in relation to travellers, but in
relation to the permanent parking of caravans and other vehicles which have
been adapted and used for permanent residential use on streets in Bristol. This
is particularly the case near open spaces and particularly so around the Downs.
This gives rise to concerns in relation to rubbish and sanitation. Additionally
on the Downs these are parked in locations where the duration of parking is
controlled for the general public to enable the parking to be available for
recreational users of the Downs. Over time the number of caravans parked on the
Downs has grown, so that around 50 caravans are now to be found parked in one
of the city’s most used public open spaces.
The council
is to redevelop its Caravan Club site in the Harbourside for housing and we are
not aware that an alternative site has yet been granted planning permission.
We consider
that the Local Plan should identify a site for permanent use with suitable
amenities for use by those that currently use the public highway for this
purpose, due to the harm to the character and amenity of the City’s open
spaces.
