Don’t miss a unique opportunity to discourage tall buildings – comment on the Draft Local Plan by January 20!

The Local Plan is important because it “will set out how Bristol will develop over the next 20 years” (quote from the Council’s “Review”). The sting in the tail for the city is that it has to implement (as in must implement) new national policies with a very strong requirement for local democratic involvement(as in really local). These new national policies have obvious implications for tall buildings because few areas in Bristol would voluntarily draw up codes which include tall buildings.

I was alerted to this by the Bristol Draft Local Plan itself, which says:

“10.3 The approach to design set out in national planning policy and guidance has changed. All local planning authorities are expected to prepare local design guides or codes that contain their detailed design guidance. Design guidance is to be developed in partnership with local communities. Local planning authorities are no longer expected to set out detailed development management policies for design in their local plans.”

This refers to the new National Design Guide and particularly the National Model Design Code (NMDC). The second new national document is amazing, in fact revolutionary. It includes a very strong requirement for local democratic involvement, which it calls “co-design”.

However the Bristol Draft Local Plan paragraphs 10.5 and 10.6 alarmingly imply that planning guidance is to be achieved largely by referring to previous top-down policies “Policies consulted on previously in the 2019 local plan review consultation”. (These included, notably, policies on tall buildings) and “Existing relevant planning guidance such as the Urban Living SPD..” You’ll recall that the popular responses to the SPD consultation on tall buildings were largely ignored by the city administration.

This top-down disregard of popular opinion is emphatically not what the new national policies have in mind.

Each community is to co-design its own environment

On the contrary, under the new national rules each local community is expected to be a co-designer of its own environment. This is a big change. It is not acceptable if in practice the community’s desires are over-ruled. So we need to know how this “co-design” is to happen.

This is made clear in the National Model Design Code (eg Part 1) see Paras 14, says that “Design codes should be prepared in light of information about what is popular locally, on the basis of evidence. This will address the ambition in the new planning system to bring democracy forward so that communities decide what good design means locally and that this is enshrined in design codes and guides.” Paras 16: 9. The National Planning Policy Framework is clear that design policies should be developed with local communities, so they reflect local aspirations.”

The subsequent pages of the National Model Design Code sets out advice on this, and it seems that Bristol’s draft local plan has not really taken the advice on local democratic input to heart, and not worked sufficiently on it.

Also consider: National Model Design Code Part 2 – Guidance Notes See Paras

220: When preparing design codes, communities need to be involved at each stage of the process… The form and approach for community engagement needs to be decided locally and co-designed with community groups.

That is clear enough. Is it being done?

221. The community involves all people living and working in and around the area for which the code is being produced together with local interest groups, stakeholders and elected representatives.

223. The process should be transparent and collaborative and precede each stage of the design code production… At each stage, it should be easy for participants to engage with the process and see how their inputs have been used to develop the next iteration.

“The process should be transparent.” The obvious locus of transparency, which councillors, politicians and local campaign groups refer is the Local Plan. So why are the procedures to be adopted, or at least how they are to be developed, not in the Local Plan?

Also see NMDC p 87 on community engagement tools, 88 on community engagement, paras 232 and 233 on measuring community support, and Planning Practice Guidance, Design: Process and Tools. These local engagement and local engagement tools are, as is evidenced by the amount of space given to them, not minor aspects of the new nationally-mandated requirements, but central.

The need for the Bristol Local Plan to specify processes

However it very much feels as if Bristol Council finds this awkward and is embarrassed by it, and is not prepared to adapt its practice to meet the new requirements for local “co-design”, but has decided to produce a lot of text apparently adapting to the new situation (lists of ambitions which correspond to those in the national documents, e.g.), but in practice changing little and continuing to behave in the same way as before.

The Draft Bristol Local Plan paragraphs 10.5 and 10.6 refer to Appendix 3, which sets out a rather reasonable view of the areas of design guidance which should be “developed in partnership”. But the pious hopes enunciated are not enough, we need some specification of the processes to be followed at local level. Since the national documents cannot specify the processes (it would have been impossible – a village must clearly have different planning processes to parts of Manchester or Bristol) the processes have to be locally developed. If these processes are not developed and specified, it will be impossible to criticise our politicians for not giving sufficient weight to local opinion. Equally, we know it is too much to expect of our councillors to criticise the city’s procedures by reference to the national documents – if they don’t do so now, why should they in future?

So we should NOT accept the Draft Local plan’s Appendix 3 as a sufficient fulfillment of the new national policies in this area. We need to ask for something more. We want actual processes by which local co-design can be implemented, and standards to which we can hold our politicians. Remember, this Local Plan will rule us, it is claimed, for 20 years, so getting it right is important.

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