Sites and Policies Plan Consultation Draft

Comment ID 3303905//1
Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM3-8 View all on this section
Respondent T Belsten View all by this respondent
Response Date 18 Apr 2013

Regarding DM3 (“Heritage assets”), we suggest a few small but important,

amendments. The bullet-point “

It will secure the long term future of the historic asset

and where applicable its continued use for a purpose sympathetic to conservation

” may be

more clear if amended to “

It will secure the long term future of the historic asset and

where applicable,

continue its current use for a purpose sympathetic to conservation”. In

addition, where the Core Strategy policies are mentioned, we feel relevant

National Planning Policy Framework (NPPF) guidelines should be quoted, such as

guidelines 17, 126, 128, 129, 130, 131, 132, 133, 141 and maybe 65, 126 and

134. Doing so will confirm compliance with nationally approved guidelines. A

number of these guidelines should also be considered mentioning for DM5

(“Listed Buildings”).

Similarly, with DM8 (“Non-designated heritage assets”) NPPF guidelines 135, 139,

141 and 169 would be worthwhile mentioning as being connected.

Regarding DM4 (Conservation Areas”), we value and give our support for this. We

suggest its relationship to NPPF guidelines 137 & 138 should be added to the

Core Strategy policies quoted within it.

Under the background of DM71 (“Protection of sporting, cultural and community

provision”), we would like to suggest an insertion of words in condition (d), to

read as follows:

d) the local planning authority, through consultation with relevant council

departments, town/parish councils, service providers and voluntary groups,


both local and national

etc. is satisfied that there is no demand for any form

of community facility in the vicinity

and for this to be followed by a further bullet-point:


There are no present or expected development plans on local or neighbouring

sites such as an expansion of housing, business or industry, which would

create a sufficient degree of demand to revive the community facility.

These refinements would allow for recognition of comments by bodies such as

ours, to assist local neighbourhoods in protecting their assets and prevent the

loss of community facilities only to have need to build them again later. To do so

would be wasteful of existing structures and future raw materials, and risk later

damage to the local character of the area. This protection would also be in

compliance with the second bullet-point of NPPF guideline 70.

You may be aware of Bristol City Council having proposed a policy - DM6 - to take

the protection of public houses (“pubs”) as community facilities further. They have

taken on board some further refinement we proposed during their consultation


We encourage you to consider an equivalent policy. We suggest one further

below. Drawing on the compliance with your policies CS5 (“Landscape and the

Historic Environment”), CS12 (“Achieving high quality design and place-making”)

and CS27 (“Sport, Recreation and Community Facilities”), our proposal would also

strengthen the sister proposed policies DM3 (“Heritage Assets”), DM5 (“Listed

Buildings”) and DM8 (Non-designated heritage assets”), and follow NPPF guideline


Pubs are well recognised as vital places for community cohesion and interaction,

helping people of various cultures and ages to integrate. They raise the health

and quality of community life. This can be vital in both rural and suburban areas

where the business and residential population may be either scattered or mixed.

Pubs provide drinking, eating, entertainment including games, quizzes and music,

along with relaxation for reading, meeting places for friends, families and interest

groups. They can also be the heart for supporting sports, arts and charities.

These environments are a strong part of our country's heritage for their character

and purpose. Our country's pubs through their architecture and purpose, have

their own styles of features including etched or stained & leaded windows,

signage, crafted woodwork and stonework, along with features such as cellar

doors, brewers’ plaques and hangman signs on their shopfronts. Engraving of

phrases such as “Ales, porters and stouts”, and etching on windows such as

“Saloon bar”, “Lounge”, “Tap room” are examples of such distinct character.

Internally, woodwork such as the bar counters, bar backs, screens, furniture

(sometimes fixed) and mirrors help preserve their unique character. In addition, a

number have been recognised for their own unique history of events and visitors

over the centuries. Such details must not be lost.

These facts lead to their being valuable tourist attractions. In addition, pubs are

often valuable landmark buildings. They can even act like sign posts when

directing people from A to B. It is a common practice to guide visitors via the “Red

Lion”, “White Hart”, “Queen’s Head”, “King George”, etc!

Pubs also act as one of the early stepping stones for the employment of young

people, in addition to being supportive of longer-term posts including cellarmen,

cooks, cleaners, accountants - not to forget brewers! They are also valuable

components of their local economies, working with their neighbours such as

shops and attracting more customers to their area. Their hours of trade should

also be remembered - commonly from late morning through the day into the

evening and the late night economy. They highly support businesses such as

take-away shops and taxi-drivers in the night-life.

We have experienced an accelerating loss of pubs in the past decade and more.

Many of these have been conversions to flats, supermarkets or offices - or just

plain demolitions with no development. This has diluted the choice of places to

visit. In a number of cases, accessibility to those remaining has proved more

difficult for people on foot. Some neighbourhoods have been left with no such

community facility remaining. Often, potential publicans wishing to buy the pubs

have been ignored by the owners when showing an interest.

A number of pubs converted have lost recognition for their shopfronts. Some

applications we have seen have included extensions and increases in elevations.

Due to this, we feel a protection for pubs would also link with your policy CS12

(“Achieving High Quality Design and Place-Making”) and strengthen the intentions

of sister proposed policies DM37 (“Residential development within settlement

boundaries in existing residential areas and on garden land”) and DM39

(“Conversions and subdivisions to residential use outside the Areas of Restricted


With an expansion of dwellings expected in the coming years, there will be more

need for facilities such as pubs, especially with the population increasing. This

makes it vital that existing ones are not lost.

On this basis, we propose a policy to the effect of the following:

Core Strategy policies - CS5, CS12, CS27 and NPPF guidelines 23, 70

Policy Intentions

Protect and retain the diversity, vitality, health and morale of neighbourhoods and city


Retain a balance of buildings in neighbourhoods;

Retain a diverse mixture of buildings in town centres;

Protect the shopfronts and other features which distinguish the nature and history of these


Reinforce protection from “garden-grabbing”. [This can be removed if DM37 remains the



There has been a high loss of these distinct, traditional community facilities over the years.

Pubs provide important meeting places for social cohesion, venues for meetings, night

classes, play areas for children in addition to places for drinking and dining. They are also

well known for their support of sports, arts and charities. In addition, the buildings can make

distinct landmarks, having sometimes been the initial buildings in neighbourhoods, causing

the housing and shopping areas to later develop around them. Some are listed with English

Heritage; a number are non-designated heritage assets worthy of being locally listed.

Policy DM nnn - Protection of Public Houses

Proposals to remove a public house will not be accepted unless:


The public house can be proved to no longer be economically viable, using the

Campaign for Real Ale's Public House Viability Test. The evidence will be submitted

by the Council to an independent body for assessment, with the costs met by the


The applicant has to provide evidence of the pub having been marketed at a fair

price as a going concern with all interested parties given consideration, for a

minimum of 12 months prior to the submission of the application;

Evidence of the pub’s promotion whilst trading must be produced;

A diverse range of other public houses are trading in the locality, within five minutes

walking distance (by a person with an average state of mobility) of the proposed


Where development is permitted, any extensions or alterations should not harm the identity

or architectural character of the public house.

We hope you will give strong, positive consideration to our proposals.