Over 36 people co-created a community response to the Council’s Public Consultation in June/July on Bus Rapid Transit phase 3 (North Fringe to Hengrove). Our response related to Zone 4 of that which includes the M32 bus only junction.
Here in full is our letter we collectively submitted to the ‘consultation’ stating in 9 points our reasons for wanting better solutions. It’s a surprisingly good read!!
Re: BRT North Fringe to Hengrove Consultation (Zone 4). 15 July 2012
We the undersigned are members of the local community connected to the area around the propsed new motorway junction in Zone 4 of the proposed Bus Rapid Transit route. We are either local residents or members of the Bristol community with connections to, and interests in, this area.
On 3rd July a community meeting was held to discuss the Zone 4 proposals, in particular the new bus route / roundabout / motorway junction that is proposed and how it will impact upon the land and the community. While we are in favour of low carbon, public transport solutions we are strongly opposed to the proposed BRT route as it is currently proposed.
- The new junction on the M32 is not needed for a bus rapid transit route from the north Bristol fringes to the city centre. It is purely there for access to a Park and Ride (see point 2). The BRT route could run from UWE along the newly-widened A4174 to Junction 1 on the M32, with additional road widening and junction improvements as required. The scheme as proposed, with a new bridge, a new motorway junction and an entirely unneccessary roundabout would be a waste of public money given that they are not necessary for the stated purposes of the BRT.
- The only reason for building a new bridge and junction is to serve a new M32 Park and Ride. The current consultation is deliberately deceptive, stating that the new roundabout is needed ‘to allow errant traffic to return to the M32’. It is clear that this is not the case. The new roundabout, with the stub exit clearly visible, has been planned to allow for the subsequent construction of a Park and Ride. Bristol’s Core Strategy does include plans for an M32 Park and Ride but a site is not given. We feel that this site is entirely unsuitable for a Park and Ride. The National Planning Policy Framework states that within Green Belt, the only acceptable development of this type is:
“local transport infrastructure which can demonstrate a requirement for a Green Belt location”.
No evidence or argument has been presented to show that a Green Belt location would be required for an M32 Park and Ride. Given that, the current scheme would use considerable amounts of money to create the infrastructure for a development that would not meet the requirements of the NPPF.
- It is on rare and irreplaceable Grade 1 agricultural land which should be used for market gardening and allotments to feed Bristol and to support the health and wellbeing of the local community. This forms only 3% of UK land; much of this 3% is in Lincolnshire and other eastern counties and only a few small areas exist around Bristol. The National Planning Policy framework states:
“112. Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.”
The site of the new motorway junction, bridge and roundabout and the Park and Ride site that they are designed to serve are all on Grade 1 agricultural land. This site forms part of the ‘Blue Finger’, a strip of Grade 1 Agricultural land running northwards alongside the M32 into South Gloucestershire. This optimum quality soil only covers 3% of the UK. No justification has been given for using this precious land rather than land of poorer quality. The scheme as presented is thus not compliant with the requirements of the NPPF. The Strategic Environmental Assesment for the West of England Joint Local Transport Plan 3 states“Soil erosion is a key concern in the South West. Soils and agricultural land are also under pressure from new development. Soil is needed for food production and serves a number of other uses (such as the cycling of nutrients, and storage of carbon). The protection of soil is therefore an important consideration in sustainable development”. The proposals are clearly in contravention of this guidance.
Bristol’s Food Policy Council, supported by Bristol City Council, has also called for planning decisions to take food issues into account. This has clearly not been the case in this proposal, which sets the city on a course to lose a substantial area of Grade 1 Agricultural land in a highly accessible location, which is already the focus of community food growing activities. The recommendations of the ‘Who Feeds Bristol’ report, also supported by BCC, include the ambitions to:
“Safeguard land for food”
“Increase urban food production”
“Protect key infrastructure for local food”
“Support community food enterprise models”
Again, this proposal runs counter to these aims.
- Bristol’s Core Strategy Policy BCS9 states:
“The integrity and connectivity of the strategic green infrastructure network will be maintained, protected and enhanced.“
A Park and Ride on this site would damage the integrity and connectivity of the vital green corridor alongside the M32 and would therefore be against the aims of this policy.
- The proposed site for the Park and Ride is also unsuitable in transport terms. Given that the consultation documentation shows there will be a number of Park and Ride sites serving the communities on either side of the M32, any new M32 Park and Ride will be primarily for people entering Bristol from the M4 / M32. A new M32 Park and Ride should therefore be sited as far north on the M32 as possible to reduce congestion at the M4/M32 junction and on J1 of the M32. Ideally it should be sited north of the M4/M32 junction and accessed from that junction. In any case, the proposed new bridge and junction for the BRT scheme should not be built unless and until the evidence of need for a Park and Ride at that particular location has been presented and scrutinised. It is entirely inappropriate to build the infrastructure for the new Park and Ride without a proper process of consultation for the Park and Ride itself.
- The scheme as proposed, even without the Park and Ride, will damage the biodiversity of the area; destroy rare and irreplaceable highest quality food growing land; damage the character of the neighbourhood; reduce the number of allotments available to local people during the construction process at a time when there is already a waiting list for allotments; place existing allotments at risk of pollution; create air, light and noise pollution; and damage additional land during the construction phase. Given that the new bridge and roundabout are only required as a precursor to a new Park and Ride, we feel that the scheme should be changed so that the BRT route uses existing road infrastructure.
- In recent years Bristol has developed a reputation as a ‘green’ city, with a strong reputation around local food issues. This culminated in the Green Capital 2014 bid. We feel strongly that Bristol City Council and South Gloucestershire Council should recognise the unique value and heritage of the high-quality agricultural land that runs northwards alongside the M32 from Stapleton and ultimately beyond the M4. This is Bristol’s historic market gardening quarter, with a long and highly productive history of growing food and plants for the city, and based on a piece of land with extremely high-quality soil. Grade 1 agricultural land is nationally extremely rare and in Bristol’s immediate surroundings it is rarer still. This land is capable of sustainable food production on a large scale, developing Bristol’s food security, reducing ‘food miles’, building the local distinctiveness of food culture in the city and giving the local community access to the green spaces and fresh food that are vital for their health and wellbeing. Bristol’s Core Strategy states [4.20.1]: “The policy aims to ensure that all development maximises opportunities to re-use previously developed land and also uses land in the most efficient way possible. “
Using Grade 1 agricultural land for a Park and Ride site does not represent the most efficient possible use of that land.
Bristol City Council and South Gloucestershire Council should work together in cross-border cooperation as required by the Localism Act to assess and evidence the need for a new Park and Ride site; if an additional site is required, a new location should be found by the two councils that does not damage the long-term sustainability of the city. Ideally this site would be on previously developed land as required by Bristol’s Core Strategy Policy BCS20.
- Bristol’s Core Strategy policy BCS9 states:
“Appropriate mitigation of the lost green infrastructure assets will be required.”
We strongly oppose the construction of a new bridge, roundabout and motorway junction. The inappropriateness of the scheme is compounded by the lack of proper mitigation being offered. The scheme as proposed involves a significant reduction in the quality of allotment plots and a significant reduction in the land being made available for community agriculture, as well as the permanent loss of irreplaceable Grade 1 land and significant damage to green infrastructure and damage to the capacity of the city for long-term sustainability. In these circumstances the proposed mitigation is entirely inadequate.
- The consultation process for the BRT scheme has been inadequate and misleading. No rationale has been presented for the new motorway junction. The only possible reason for the scheme as proposed is to provide infrastructure for a future Park and Ride, and yet the consultation materials not only fail to mention this, but are deliberately deceptive, labelling the access roundabout for the Park and Ride as being “to allow errant vehicles to return to the M32”. This is a clear attempt to avoid public discussion on the Park and Ride site so as to later present the Park and Ride as inevitable, bypassing proper consultation and community involvement.